Analyzing the compliance and reimbursement impact of OPPS and MPFS updates
by Kimberly Hoy, JD, CPC
I’m excited to be covering the Outpatient Prospective Payment System (OPPS) and Medical Physician Fee Schedule (MPFS) proposed rules with my colleague Amy Inch, CPC, CPMA, Medicare regulatory specialist at HCPro, this year at the 2026 Revenue Integrity Symposium (RIS), to be held September 24-25 in Savannah, Georgia, during our day two general session “Regulatory Roundup: Proposed and Final Rules: OPPS, IPPS, and MPFS”. Although the proposed rules will likely not be released until later this summer, there are several significant issues that are likely to be addressed in them based on the 2026 rules and CMS’ current focus. There are many unknowns in the new requirements for National Provider Identifiers (NPI) and attestations for off-campus provider-based departments (PBD) and I’m anxious to see what CMS does with those. We’re also likely to see more removals from the inpatient-only list; it’s going to be interesting to see how CMS incorporates those into the existing Ambulatory Payment Classification (APC) structure. Site neutrality is also likely to continue to be an issue. I’m interested to see if additional services will be added to the list receiving the 60% off-campus PBD reduction.
Many of these changes will heavily affect PBDs and I am also doing a separate session on common issues and misunderstandings in provider-based department (PBD space) on day one, “Provider-Based Confusion Sorted Out”. My co-speaker for that session, C.J. Tonozzi, CPCI, CPRC, CRCS, CCT, compliance officer at OSF HealthCare in Peoria, Illinois, will discuss their challenges, the lobbying activity they’ve engaged in around the new off-campus requirements, and the excess burden it’s likely to place on both the providers and CMS.
In addition to my sessions, I’m looking forward to seeing all the colleagues and friends I meet year after year at this event. I’ve been attending this event, or the predecessor HCPro event, for over 15 years and there are people I look forward to seeing and catching up with year after year. I’ve seen some of these folks move from attendees to presenters as their knowledge and experience grows.
We are in a time of great change in the hospital revenue cycle space. Our challenges range from struggling to keep up with the coding and billing of an ever-increasing number of new technologies to the pressure of reduced reimbursement from both government and private payers. Understanding the complex rules that underpin the revenue cycle is a first step in defending against these challenges and RIS is a great opportunity to increase your knowledge level while making great networking contacts who are struggling with the same challenges.
About the author
Hoy is a senior regulatory specialist for HCPro. She is the lead instructor for HCPro's Medicare Boot Camp - Hospital Version, Utilization Review Version, and Provider-Based Department Version and HCPro's Revenue Integrity and Chargemaster Boot Camp. She is also an instructor for HCPro's Medicare Boot Camp - Critical Access Hospital Version and Rural Health Clinic Version. She is a former hospital compliance officer and in-house legal counsel, with over 30 years of healthcare experience. The majority of her career has been focused on teaching, speaking, and writing about Medicare coverage, coding, and payment regulations and requirements.