On November 4, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued the Calendar Year (“CY”) 2027 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center (“ASC”) Payment System final rule (the “Final Rule”), following the July 2, 2026, proposed rule and the public comment period. The Final Rule increases average payment rates for covered ASC procedures, adds hundreds of procedures to the ASC Covered Procedures List (“ASC-CPL”), removes hundreds of procedures from the Inpatient Only List (“IPO List”) and revises the ASC Quality Reporting Program (“ASCQR Program”).
Background: Recent Expansion of the ASC-CPL
CMS’s approach to the ASC-CPL has shifted in recent years. After expanding the list in CY 2021, CMS substantially reversed course the following year, but it has since moved toward broader access to procedures in the ASC setting. The CY 2026 final rule continued that trend by adding 289 procedures to the ASC-CPL and beginning a three-year phaseout of the IPO List.
Overview of Changes for CY 2027
On average, ASCs will see a 2.3% payment increase, reflecting a 3.2% market basket update reduced by a 0.9% productivity adjustment. Because that figure is an average, the effect on individual services will vary significantly. CMS reduced the ASC weight scalar from approximately 0.872 for CY 2026 to 0.814 for CY 2027, which lowers payment for a number of common, non-device-intensive procedures despite the positive overall update. Each of the ten most frequently performed ASC procedures, including certain ophthalmology, gastroenterology and pain management services, will see lower reimbursement in CY 2027 than in CY 2026. ASCs should therefore evaluate the final rates at the procedure and specialty level rather than relying on the 2.3% headline increase.
The Final Rule also continues the phaseout of the IPO List by removing 637 additional services and expands the ASC-CPL by 618 procedures, including many procedures removed from the IPO List. The additions include all four hernia codes requested by the Ambulatory Surgical Center Association and CPT code 64629, which is an add-on code for imaging guided thermal destruction of the intraosseous basivertebral nerve CMS added in response to public comments. The complete list of additions is available in the Final Rule. Unlike the 2026 additions, which were weighted toward cardiovascular procedures, the CY 2027 additions are spread across a broader range of specialties, including respiratory, digestive, endocrine, auditory and urinary procedures.
The CY 2027 additions signal that CMS continues to expand access to surgical procedures in the lower-cost ASC setting, informed by physician feedback and public comments, while maintaining its focus on patient safety. They also reflect CMS’s emphasis on physician flexibility as medical advances expand the procedures appropriate for outpatient care.
In addition to changes to the ASC-CPL, CMS removed the ASC-9: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients measure from the ASCQR Program beginning with the CY 2027 reporting period. The removal will affect payment determinations beginning in CY 2029. No further changes to the ASCQR Program were finalized.
Practical Takeaways
- Stress-test your CY 2027 financial projections. The expanded ASC-CPL and continued IPO List phaseout may bring more procedures to ASCs, but higher volume will not improve margins if reimbursement per procedure declines. ASCs should compare CY 2027 and CY 2026 payment for their highest-volume procedures, including the ten most frequently performed ASC procedures, which will all see lower reimbursement, and update budgets and pro formas accordingly.
- Evaluate new service lines procedure by procedure. Before adding any newly covered procedure, ASCs should model the CY 2027 payment rate against anticipated supply and implant costs, equipment needs, staffing and surgeon demand. The lower ASC weight scalar means that payment for some non-device-intensive procedures may not support the investment.
- Review payer contracts and rate-setting terms. To the extent payer agreements or internal fee schedules are tied to Medicare ASC rates, ASCs should determine how the CY 2027 changes will flow through to those rates and whether renegotiation is warranted.
- Revisit ownership and investor strategy with counsel. Newly covered procedures may expand the physician specialties that can use and potentially invest in ASCs. Before offering ownership to physicians in new specialties, ASCs and physician groups should confirm that the arrangement meets applicable Anti-Kickback Statute safe harbor and state law requirements, and should update operating agreements and investor selection criteria as needed.
- Update quality reporting processes. ASCs should confirm that their ASCQR Program reporting workflows reflect the removal of the ASC-9 colonoscopy follow-up interval measure and that they continue to meet the remaining program requirements.
- Build an implementation plan before January 1, 2027. ASCs and physicians should identify relevant newly covered procedures and assign responsibility for the credentialing, staffing, billing and compliance changes needed for each. Completing that work before the effective date helps avoid delays and claim errors once the new rates take effect.
If you have any questions or would like additional information about this topic, please contact:
- Jennifer Struck at (317) 429-3674 or jstruck@hallrender.com;
- Mark Adams at (248) 457-7868 or madams@hallrender.com;
- Matt Decker at (248) 457-7867 or mdecker@hallrender.com;
- Chad Sukurs at (317) 977-1452 or csukurs@hallrender.com;
- James Willey at (317) 977-1409 or jwilley@hallrender.com;
- Bennett Murphy at (317) 429-3618 or bmurphy@hallrender.com;
- Kiera Gauthier at (720) 614-6421 or kgauthier@hallrender.com;
- McKenna Schaefer at (317) 429-3611 or mschaefer@hallrender.com;
- Alessandra Ruano at (919) 228-2413 or aruano@hallrender.com; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
