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CMS WatchNovember 6, 2026·5 min read

CY2027 OPPS/ASC final: 637 IPO removals, 618 ASC CPL adds, and 340B at ASP−28%

CMS published the CY2027 OPPS/ASC final rule (CMS-1850-FC) in the Federal Register on November 6, 2026. It removes 637 services from the inpatient-only list, adds 618 codes to the ASC Covered Procedures List, pays 340B drugs at ASP minus 28%, and expands hospital OPD prior authorization to eight more botulinum toxin injection codes. Most policies take effect January 1, 2027.

OPPSASCCY2027IPO listCMS
HCC Buddy

By the HCC Buddy Coding Team

Published November 6, 2026

Outpatient coding desk with a setting-of-care clipboard, procedure folder stack, and January calendar for the CY2027 OPPS and ASC final rule
CMS published the CY2027 OPPS/ASC final rule (CMS-1850-FC) on November 6, 2026, with most payment and list changes effective January 1, 2027. — Illustration: HCC Buddy

Key Takeaways

  • →On November 6, 2026, the Federal Register published the CY2027 Hospital OPPS and ASC Payment Systems final rule with comment period (CMS-1850-FC), after CMS issued the fact sheet and press release on November 4, 2026. Most provisions are effective January 1, 2027.
  • →CMS is increasing OPPS and ASC payment rates by 2.3% for providers that meet applicable quality reporting requirements (3.2% market basket minus a 0.9 percentage point productivity adjustment).
  • →In year two of the inpatient-only (IPO) list phase-out, CMS is removing 637 services across auditory, digestive, endocrine, female genital, hemic and lymphatic, integumentary, male genital, maternity, mediastinum and diaphragm, respiratory, and urinary clinical families, and is adding 618 codes to the ASC Covered Procedures List.
  • →For CY2027, CMS is paying 340B-acquired drugs at Average Sales Price (ASP) minus 28%, and is raising the annual non-drug conversion-factor offset from 0.5% to 2% (excluding hospitals that enrolled after January 1, 2018) until the $7.8 billion remedy total is reached (CMS estimates CY2031).
  • →CMS is expanding hospital outpatient department prior authorization to eight additional botulinum toxin injection codes for dates of service on or after July 1, 2027, and is applying Physician Fee Schedule-equivalent rates to imaging without contrast services in excepted off-campus provider-based departments (rural Sole Community Hospitals exempt).

On November 6, 2026, the Federal Register published the CY2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems final rule with comment period, CMS-1850-FC. CMS had issued the fact sheet and press release on November 4, 2026. Most provisions take effect January 1, 2027. This is the annual OPPS/ASC package, not the same thing as the quarterly October 2026 OPPS update CR 14589 already on /news.

Setting-of-care clipboard and ASC procedure folder on an outpatient coding desk
Year two of the IPO phase-out moves hundreds of procedures off the inpatient-only list and onto outpatient and ASC options.

Payment update: +2.3% for OPPS and ASC

CMS is finalizing a 2.3% update to OPPS payment rates for hospitals that meet applicable quality reporting requirements, based on a 3.2% projected hospital market basket increase reduced by a 0.9 percentage point productivity adjustment. ASC rates that meet quality reporting requirements get the same 2.3% update factor under the continued hospital-market-basket alignment through CY2027.

CMS estimates the package touches roughly 3,500 hospitals and 6,400 ASCs. Hospitals that fail outpatient quality reporting still take the statutory 2.0 percentage point reduction (reporting factor 0.9804).

IPO list: 637 removals in year two of the phase-out

CMS is continuing a three-year phase-out of the inpatient-only (IPO) list. For CY2027 (year two), it is removing 637 services from these clinical families: auditory, digestive, endocrine, female genital, hemic and lymphatic systems, integumentary, male genital, maternity care and delivery, mediastinum and diaphragm, respiratory, and urinary.

That is a setting-of-care coding change, not a diagnosis change. Procedures that sat on the IPO list could only be paid as inpatient. Once they come off, Medicare can pay them in the hospital outpatient department when the clinician decides that setting is clinically appropriate. Pull the CMS addenda on the CMS-1850-FC regulations page before you rewrite scrubber or charge-master rules for those HCPCS lines.

ASC Covered Procedures List gains 618 codes

Alongside the IPO removals, CMS is adding 618 codes to the ASC Covered Procedures List (CPL), including procedures recommended by commenters and nearly all of the services removed from the IPO list for CY2027. For ASC billers, that means a large new set of codes can be paid in the ASC setting starting January 1, 2027. Check the ASC addenda before you open a code that was blocked in CY2026.

ItemCY2027 final
OPPS / ASC update (quality reporters)+2.3% (3.2% − 0.9 productivity)
IPO list removals637 services (year 2 of phase-out)
ASC CPL additions618 codes
340B drug paymentASP − 28%
Non-drug 340B remedy offset0.5% → 2% (enrolled after 1/1/2018 excluded)
Imaging without contrast at excepted off-campus PBDsPFS-equivalent rate (rural SCHs exempt)
Extra botulinum toxin OPD prior auth8 codes; DOS on/after July 1, 2027

340B drugs at ASP minus 28%, and a faster non-drug offset

After the Medicare OPPS Drugs Acquisition Cost Survey (January 1 through April 7, 2026), CMS is finalizing payment for 340B-acquired drugs at ASP minus 28%. The fact sheet estimates that change reduces Original Medicare drug payment by $4.35 billion and beneficiary drug payments by $1.1 billion in the first year, implemented budget-neutrally so non-drug OPPS payments rise by an equivalent amount (the Federal Register summary cites about a 7.50% increase to non-drug service payments for this final).

Separately, the 340B remedy offset on the OPPS conversion factor for non-drug items and services rises from 0.5% to 2% for CY2027 for hospitals subject to the offset (hospitals that enrolled in Medicare after January 1, 2018 stay excluded). CMS estimates the aggregate $7.8 billion non-drug overpayment recovery finishes around CY2031 under the faster pace.

Site-neutral imaging and botulinum toxin prior auth

CMS is expanding its volume-control method for excepted off-campus provider-based departments to imaging without contrast services (certain bone density scans, x-rays, ultrasounds, CT scans, and MRIs), paying the Physician Fee Schedule-equivalent rate instead of the full OPPS rate. Rural Sole Community Hospitals stay exempt, matching the clinic-visit and drug-administration policies already in place. CMS estimates about $260 million in Part B savings in the first year.

On program integrity, CMS is finalizing prior authorization for eight additional botulinum toxin injection codes in the hospital outpatient department for dates of service on or after July 1, 2027. That is a mid-year operations date, not a January 1 cliff. Build the PA workflow against the code list in the final rule and addenda before summer.

CMS is also renaming algorithm-based software services from "Software as a Service" (SaaS) to "Software as a Medical Service" (SaMS) for Medicare payment purposes, with interim New Technology APC assignments, and is moving certain stand-alone algorithmic analyses of prior lab tests from the Clinical Laboratory Fee Schedule onto the OPPS as other diagnostic tests.

What this does and does not change for risk-adjustment desks

This rule rewrites outpatient and ASC payment, packaging, and setting lists. It does not rewrite Medicare Advantage HCC mappings or ICD-10-CM diagnosis rules. When an outpatient encounter also feeds an MA chart, keep using the Code Book and encoder / RAF calculator for the diagnosis side. For Part B fee-schedule coding that landed the same week, see the separate CY2027 PFS final (G2211 → modifier B1; same-day E/M with 0-day globals at 80%).

What to do before January 1, 2027

Download the CMS fact sheet, the published Federal Register text, and the OPPS/ASC addenda from the CMS-1850-FC page. Diff your IPO and ASC CPL files against the CY2027 lists. Flag the eight new botulinum toxin prior-auth codes for a July 1, 2027 go-live. Model 340B line pricing at ASP−28% and the 2% non-drug offset if your hospital is in the remedy group. And treat imaging without contrast at excepted off-campus PBDs as PFS-equivalent unless you are a rural Sole Community Hospital.

What coders should do now

  1. 1Diff your IPO and ASC Covered Procedures List files against the CY2027 CMS-1850-FC addenda before January 1, 2027: 637 IPO removals and 618 ASC CPL additions change which settings pay.
  2. 2Rebuild scrubber / charge-master blocks that still treat the removed IPO HCPCS as inpatient-only; confirm clinical documentation supports the outpatient or ASC setting when those codes move.
  3. 3Calendar the eight additional botulinum toxin injection prior-authorization codes for hospital OPD dates of service on or after July 1, 2027. That tranche is mid-year, not January 1.
  4. 4If your hospital bills 340B drugs under OPPS, model ASP minus 28% pricing and, if subject to the remedy offset, the 2% non-drug conversion-factor reduction for CY2027.
  5. 5For excepted off-campus PBDs, apply PFS-equivalent rates to imaging without contrast APC HCPCS (rural Sole Community Hospitals exempt), consistent with existing clinic-visit and drug-administration site-neutral rules.

Frequently Asked Questions

When does the CY2027 OPPS/ASC final rule take effect?

Most provisions of CMS-1850-FC are effective January 1, 2027. CMS posted the fact sheet and press release on November 4, 2026, and the Federal Register published the rule on November 6, 2026. The expansion of hospital OPD prior authorization to eight additional botulinum toxin injection codes applies to dates of service on or after July 1, 2027.

Is this the same as the October 2026 OPPS update (CR 14589)?

No. CR 14589 is a quarterly OPPS claims-processing update. CMS-1850-FC is the annual CY2027 OPPS/ASC payment system final rule that sets rates, the IPO list, the ASC CPL, 340B drug payment, and related policies for calendar year 2027.

How many procedures leave the inpatient-only list and join the ASC CPL?

CMS is removing 637 services from the IPO list in year two of the phase-out and adding 618 codes to the ASC Covered Procedures List for CY2027. Use the CMS-1850-FC addenda for the exact HCPCS lines.

What is the finalized 340B drug payment rate under OPPS for CY2027?

CMS is paying 340B-acquired drugs at Average Sales Price (ASP) minus 28%, based on the Medicare OPPS Drugs Acquisition Cost Survey conducted January 1 through April 7, 2026. The policy is implemented budget-neutrally for non-drug OPPS payments.

Does this OPPS/ASC final rewrite Medicare Advantage HCC mappings?

No. CMS-1850-FC updates hospital outpatient and ASC payment policies. Medicare Advantage risk adjustment still runs on the CMS-HCC model and ICD-10-CM diagnosis documentation. An outpatient encounter can still feed an MA chart, but the rate, list, and packaging changes here are OPPS/ASC payment rules, not HCC mapping changes.

Related topics:OPPSASCCY2027IPO listCMS
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HCC Buddy Coding Team

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