CY 2027 OPPS Proposal: 340B Drug Payments and Imaging Site-of-Care

CMS’s proposed CY 2027 Hospital OPPS/ASC rule would adjust Medicare hospital outpatient payments for certain 340B-acquired drugs, change how some outpatient imaging is paid (including rural Sole Community Hospital exemptions), and continue the phase-out of the Inpatient Only (IPO) list. CMS also issued an RFI to improve hospital price-transparency data. The proposal is not final; comments are due August 31, 2026.

Medicare beneficiaries who receive care in a hospital outpatient department could see changes in what hospitals are paid for certain drugs and services next year. In July 2026, CMS released a proposed rule for the calendar year (CY) 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) payment updates, along with an accompanying Federal Register notice that provides additional proposal details and the official comment deadline.

Two proposals are drawing the most attention: a payment approach for many 340B-acquired outpatient drugs and an expansion of “site-neutral” payment for some outpatient imaging (with specific rural exemptions). CMS also continues the multi-year transition related to the Inpatient Only (IPO) list and asks for input on standardizing hospital price transparency data.

Quick context: what CMS is proposing (and what’s next)

CMS’s CY 2027 OPPS/ASC proposal would update Medicare payment policies and rates for hospital outpatient and ASC services for 2027, including changes related to drug payments, outpatient imaging payment, the IPO list, and a Request for Information (RFI) on hospital price transparency. (See the CMS Fact Sheet and the Federal Register notice for the proposed details.)

CMS set a public comment deadline of August 31, 2026. (Federal Register notice.)

340B outpatient drug payments: CMS proposes ASP minus 33.4%

The biggest drug-related change in the proposal concerns how Medicare pays hospitals for many separately payable outpatient drugs acquired through the 340B Drug Pricing Program when those drugs are furnished in hospital outpatient departments.

CMS proposes to pay for 340B-acquired separately payable outpatient drugs at Average Sales Price (ASP) minus 33.4%. CMS says this proposal is intended to better align Medicare payment with hospitals’ acquisition costs, using an OPPS drugs acquisition cost survey approach described in the proposal. (CMS Fact Sheet; Federal Register.)

CMS estimates the proposal would reduce Original Medicare drug payments and beneficiary drug payments in the first year, while adjusting non-drug payment amounts in a budget-neutral way as required by statute. (CMS Fact Sheet.)

What this could mean for everyday people: 340B policies affect how hospitals are reimbursed for outpatient drugs. Those payment incentives can influence hospital purchasing and outpatient pharmacy operations, which may affect how care is scheduled and billed. Your out-of-pocket costs can still vary based on the specific billed service, whether the drug is covered under Part B in your situation, and your Medicare cost-sharing. This is a proposal, so outcomes could differ in the final rule.

Background: why affordability matters for medication use

When medication costs are high, some people may delay filling prescriptions or skip doses, which can worsen outcomes for certain chronic conditions. CDC has reported that cost-related medication nonadherence is associated with worse outcomes, including higher mortality among people with certain chronic diseases. (CDC.)

Outpatient imaging: CMS proposes expanding “volume control” (with rural exemptions)

CMS also proposes changes to outpatient imaging payment intended to reduce incentives for certain services to shift into higher-paying settings.

For CY 2027, CMS proposes including imaging without contrast furnished in excepted off-campus provider-based departments under the same “volume control” logic used for some other outpatient services. (CMS Fact Sheet.)

CMS describes applying a Physician Fee Schedule (PFS) equivalent payment rate for these imaging-without-contrast services in those excepted off-campus settings, using its Social Security Act authority. (CMS Fact Sheet.)

CMS also proposes exemptions for rural Sole Community Hospitals, intended to help protect access in rural areas. (CMS Fact Sheet.)

What this could mean for access and costs: Site-of-care and payment-method changes can affect what Medicare pays, which may indirectly influence patient experiences such as scheduling, where services are offered, and how hospitals build outpatient imaging workflows. CMS’s rural exemption approach is one way the agency aims to avoid higher costs being driven purely by where care is furnished. (CMS Fact Sheet.)

Some stakeholders have raised concerns about how site-neutral policies could affect hospitals’ ability to serve complex patient populations. For example, the American Hospital Association has commented that expanding site-neutral payments for some imaging services does not fully account for the hospital outpatient setting’s role in serving patients—especially in rural and underserved communities. (AHA statement.)

Inpatient-Only (IPO) list phase-out: fewer services treated as “inpatient only”

CMS is continuing the multi-year phase-out of the Inpatient Only (IPO) list. In general, the IPO list is associated with services that Medicare typically does not pay for when furnished in a hospital outpatient setting (subject to coverage rules and exceptions governed by Medicare policy).

In the CY 2027 proposal, CMS continues this transition by proposing removal of additional services from the IPO list for CY 2027. (Federal Register notice.)

Why it can matter: CMS frames the IPO phase-out as creating more opportunities for appropriate outpatient care, which can affect where you receive treatment and how Medicare processes coverage for the service. Out-of-pocket costs may change for some people, depending on clinical appropriateness and Medicare coverage rules. (CMS Fact Sheet.)

Hospital price transparency: CMS asks how to standardize and compare data

Finally, CMS includes an RFI aimed at strengthening the standardization, comparability, and usability of hospital price transparency data—particularly how information is presented both in hospitals’ consumer-friendly displays and in the machine-readable files. (CMS Fact Sheet; Federal Register.)

What readers can do even before anything is final: If you’re planning outpatient services covered under Medicare Part B, look for the hospital’s published price information (when available) and ask the billing team what Medicare cost-sharing would likely apply for the specific service and site of care.

What’s known vs. what’s still uncertain

  • Known: CMS has published proposed CY 2027 OPPS/ASC changes covering (1) a new 340B outpatient drug payment methodology, (2) an expansion of volume-control logic for certain imaging without contrast (with rural Sole Community Hospital exemptions), (3) continued IPO list phase-out steps, and (4) a price-transparency RFI. (CMS Fact Sheet; Federal Register.)
  • Known timing: Comments are due August 31, 2026. (Federal Register notice.)
  • Uncertain: Because this is a proposed rule, the final CY 2027 payment policies and phase-out steps may change after CMS reviews public input and finalizes the rule. (CMS Fact Sheet; Federal Register.)

What readers can do now

  • For outpatient imaging: Ask where the service will be billed (hospital outpatient department vs another setting) and what Medicare cost-sharing estimate applies to that specific billed location.
  • For hospital-administered outpatient drugs: If your medication is administered as part of a hospital outpatient visit, ask how Medicare Part B billing will work for that visit and whether anything needs to be verified before treatment.
  • Use price transparency information carefully: Look for the hospital’s consumer-friendly display (and any available estimator tools) and ask billing staff to explain how the published pricing connects to your likely Medicare cost-sharing.
  • Plan for billing updates: Payment policy changes can take time to translate into scheduling and billing workflows. If you’re planning care soon, confirm expected billing details ahead of the visit.

Bottom line: CMS’s CY 2027 OPPS proposal could shift how Medicare pays for certain hospital outpatient drugs and imaging, while also advancing the IPO list phase-out and seeking better ways to standardize hospital price transparency data. The potential impact on individuals depends on the service, the site where it’s billed, and how the final rule changes CMS’s proposal. (CMS Fact Sheet; Federal Register.)

Sources

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