2026 Medicare Payment Updates: Key Proposals and Impact

Healthcare Policy Update
Jul 28, 2025
Article Background

What’s happening

On July 14th and 15th, the Centers for Medicare & Medicaid Services (CMS) posted proposed updates to the Medicare physician fee schedule (PFS) and hospital outpatient prospective payment system (OPPS) for calendar year (CY) 2026, respectively. These rules contain a number of proposed payment updates and policy changes of interest to our clients.

Of interest

For CY 2026, CMS is proposing changes to the following policies important to hospitals:

CMS proposes to eliminate the inpatient only list and expand the list of ambulatory surgical center (ASC) covered procedures. These changes would increase the range of services that can be furnished in ASCs.
CMS proposes to increase the 340B program recoupment adjustment under the OPPS.
CMS proposes to apply site neutral payment adjustments for certain drug infusion services, and the agency solicits comments on other potential site neutral policy changes.
CMS proposes new alternative payment models, including a new mandatory alternative payment model for heart failure and low back pain.

Our partners at McDermott+, one of healthcare’s most trusted and respected policy and lobbying consulting firms, wrote a summary of the proposed rules that provides valuable information about the potential changes and created a dashboard that shows the actual payment rates to hospitals and physicians for providing care to Medicare fee-for-service patients if these proposals were finalized. McDermott+ is also hosting a webinar to discuss key elements of the OPPS proposed rule and considerations when preparing comments.

Comments on the PFS proposed rule are due on September 12, 2025, and comments on the OPPS proposed rule are due on September 13, 2025.

Why you should care

The provisions included in this proposal will, if finalized, impact hospital and physician payment and quality reporting program requirements. Hospital leaders should be informed about these potential policy changes and offer feedback to CMS on how these changes will impact your organization.

Looking to learn more?

McDermott+ offers valuable insights into what these policy updates mean and how they could affect organizations. Read more to see what McDermott+ is saying about these proposals and how your organization could be impacted.

Click here for the PFS proposed rule analysis, here for the OPPS proposed rule analysis, and here for the dashboard. Register here for the webinar on the OPPS proposed rule.