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The Hospital Cash Cycle · Issue 2 · November 2026

The CY2027 OPPS rule, in cash terms

Short answer: a proposed 2.4 percent update, the 340B drug line at ASP minus 33.4 percent, the remedy offset rising to 3 percent, and site-neutral imaging. Every figure is proposed until the November final rule; each story ends with the CFO move.

CMS-1850-P · 91 FR 41733Comments closed Aug 31, 2026Final rule Nov 2026Model the drug line before the 2.4%

October 27, 20265 min readASP-RCM Solutions

Edition

Issue 2 · Nov 2026

Focus

CY2027 OPPS

Audience

Hospital CFO

Framework

CMS-1850-P

Horizon

Final rule Nov 2026

Length

5 min read

+2.4%update

Proposed CY2027 OPPS and ASC update for facilities meeting quality reporting [1]

ASP -33.4%340B drugs

Proposed Medicare payment for 340B-acquired drugs [1]

3%offset

Proposed 340B remedy offset on non-drug services, up from 0.5 percent [1]

$260Mimaging

CMS first-year estimate for site-neutral imaging without contrast at excepted off-campus departments [1]

Story 01

The 2.4 percent update and the drug line underneath it

Item	Proposed CY2027	Who feels it
OPPS and ASC update	+2.4% (3.2% market basket, 0.8 point productivity)	Every OPPS and ASCQR-reporting facility
Total OPPS payment change, all policies	+1.9% estimated across roughly 3,500 facilities	Varies sharply by drug mix and site mix
340B-acquired drug payment	ASP minus 33.4%; first-year estimate $4.55 billion less in Original Medicare drug payments	Hospitals with 340B drug volume in the outpatient department
340B remedy offset on non-drug services	Rises from 0.5% to 3% until $7.8 billion is recouped, estimated CY2029	Hospitals paid under OPPS before January 1, 2018

CFO moveModel the drug line and the 3 percent offset before the 2.4 percent. Price your CY2026 340B utilization at ASP minus 33.4 percent, apply 3 percent to the rest of the OPPS book, then add the update. That is the real CY2027 outpatient bridge.

Story 02

Site-neutral imaging at excepted off-campus departments

CMS first-year estimates for the imaging proposal, millions of dollars

PFS-equivalent rate for imaging without contrast APCs at excepted off-campus provider-based departments; rural sole community hospitals exempt [1].

Total Part B reduction

$260M100%

Program savings

$190M73%

Lower beneficiary premiums

$70M27%

Beneficiary cost sharing reduction

$70M

$0$100M$200M$300M

TotalComponentsCost sharing

CFO movePull every HCPCS code in the imaging without contrast APCs billed from an excepted off-campus department in the last 12 months, and price it at the PFS equivalent. If you are a rural sole community hospital, document the exemption now.

Story 03

Three smaller items with operational teeth

A listed service billed without a prior authorization decision is not paid [3].

Prior authorization expansion

Jul 1, 2027

Eight more botulinum toxin injection codes join the hospital OPD list; claim volume up 42.8% from 2017 to 2024 while total OPD claims fell 8.3% [2]
Owner: neurology, PM&R and infusion scheduling; see the eight new codes

Inpatient-only list

Jan 1, 2027

Removes 637 services across eleven clinical families, the second phase of the three-year phase-out [2]
Owner: utilization review and CDI

Price transparency RFI

Closed Aug 31, 2026

How to standardize MRF data, report outliers, stop-loss, tiering and carve-outs, and whether to keep estimator deemed compliance [2]
Owner: revenue integrity and managed care

CFO moveAssign the three owners this month: status criteria by December, scheduling edit by June, contract mechanism inventory before the final rule.

One thing worth 30 minutes

The 30-minute CY2027 outpatient cash bridge, five lines

Start with CY2026 OPPS cash

Line 1

Twelve months of Medicare OPPS payments, drug and non-drug split.

Reprice 340B drug lines

Line 2

Apply ASP minus 33.4 percent to 340B-acquired drug payments; note the proposed status.

Apply the 3 percent offset

Line 3

To non-drug OPPS payments, if the hospital was paid under OPPS before January 1, 2018.

Price the imaging exposure

Line 4

Imaging without contrast codes from excepted off-campus departments at the PFS equivalent.

Add the 2.4 percent update

Line 5

Then re-run the page the week the final rule publishes.

Takeaway

Keep the page; when the final rule lands you change three cells, not the method.

ASP update

Two hospital playbooks live with this issue

340B rebate model cash playbookFollows the rebate receivable from dispense to ledger on HRSA's 45-day and 10-day clocks: read it.

Price transparency MRF self-auditRecomputes the 2026 allowed-amount fields from your own 835s: read it.

Payer-side worksheetsIn the hospital denial defense toolkit; our hospital revenue cycle team will walk through the bridge with you.

FAQ

Frequently asked questions

Is the CY2027 OPPS rule final?

No, CMS-1850-P is a proposed rule issued July 2, 2026 and published July 7, 2026. Comments closed August 31, 2026 and CMS expects to finalize in November 2026, so every figure in this issue is the proposed figure.

What does the 340B remedy offset do in 2027?

CMS proposes to raise the reduction to non-drug OPPS payments from 0.5 percent to 3 percent from CY2027, excluding hospitals that enrolled in Medicare after January 1, 2018, until the estimated reduction reaches $7.8 billion, expected in CY2029.

Which hospitals are exempt from the site-neutral imaging proposal?

Rural sole community hospitals. For other hospitals, imaging without contrast APC services furnished at excepted off-campus provider-based departments would be paid at the Physician Fee Schedule equivalent rate.

Sources

PFS-equivalent rate for imaging without contrast APCs at excepted off-campus provider-based departments; rural sole community hospitals exempt [1].

Want the CY2027 bridge built on your own claims?

Send us twelve months of OPPS remits and we return the drug line, the offset, the imaging exposure and the update on one page.

Book a free audit →Past issues