Financial Implications to Hospitals Serving Substantial Percentage of Medicaid & Medicare Patients On November 21, 2025, the Centers for Medicare & Medicaid Services released its Calendar Year 2026 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule, affecting approximately 4,000 hospitals and 6,000 ASCs. The rule finalizes payment updates, policy reforms, and transparency requirements that will impact hospital and ASC operations beginning January 1, 2026. This article discusses the key OPPS changes and updates included in the Final Rule. On November 21, 2025, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY)…
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The Impact on Payment Rate Updates, Hospital Price Transparency, Rural Hospital Designation, Drug Pricing, and Intensive Outpatient Program On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) released its finalized Outpatient Prospective Payment System (OPPS) for calendar year (CY) 2024. The finalized payment update increases payments to outpatient facilities and finalizes changes to their hospital price transparency rule, among other provisions. An update to the September 2023 article on the proposed changes to the OPPS, this article discusses the various OPPS changes and updates included in the final rule. On November 2, 2023, the Centers for Medicare…
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The Aftermath of the 2022 AHA v. Azar SCOTUS Decision On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Centers (ASCs) for calendar year (CY) 2024. The agency proposes an increase in payments to all outpatient providers, introduces a new program, and announces their solution to repay 340B hospitals after their loss in the AHA v. Azar (2022) U.S. Supreme Court decision. On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the Outpatient Prospective Payment…
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COVID-19 Pandemic Deemed Over and Waivers Ending On January 30, 2023, President Joseph Biden announced that the public health emergency (PHE) and national emergency declaration related to the COVID-19 pandemic will finally end on May 11, 2023, after being in place for over three years. This article will discuss the changes that will take place after both declarations cease, and the implications for stakeholders. On January 30, 2023, President Joseph Biden announced that the public health emergency (PHE) and national emergency declaration related to the COVID-19 pandemic will finally end on May 11, 2023, after being in place for over…
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Competition (Part II of V) This second installment in this five-part series on the valuation of ASCs will discuss the competitive environment of ASCs, by competitor type. [su_pullquote align=”right”]Resources:Valuation of Ambulatory Surgery Centers—Introduction (Part I of V)[/su_pullquote] As noted in the first installment of this five-part series, an ambulatory surgery center (ASC) is a distinct entity that primarily provides outpatient surgical procedures to patients who do not require an overnight stay after the procedure.[1] The facilities typically provide relatively uncomplicated surgical procedures in a non-hospital setting, and most ASC cases are non-emergency, non-infected, and elective.[2] ASCs compete in an increasingly…
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Introduction (Part I of V) Ambulatory surgery centers (ASC) grew dramatically until 2008 and during the growth period provided services previously only available at hospitals. In this five-part series, the authors first discuss the emergence and decline of ASCs, the forces driving growth and contraction, and how the ASC business model differs from that of hospitals. The remaining articles in this series discuss: 1) the regulatory environment of the ASC industry; 2) the reimbursement environment of the ASC industry; 3) the competitive environment of the ASC industry; and 4) the technological environment of the ASC industry. These provide a brief…
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Federal Lawsuit from AHA and Four Other Providers Accuse HHS of Illegally Denying Medicare Payments Joe Carlson at Modern Healthcare reports the story: In a federal lawsuit, the American Hospital Association and four healthcare providers accuse HHS of illegally denying hospitals Medicare payments for audited outpatient procedures. The Chicago-based interest group for hospitals says in the complaint that HHS maintains an illegal policy of refusing to pay hospitals for Medicare outpatient services in cases where auditors retroactively conclude that inpatient care should have been delivered outside the hospital. “What the federal government is doing is wrong, unfair and a clear violation…