On July 2, CMS released the 2027 proposed payment rule for ASCs and hospital outpatient departments (HOPD). As ASCA noted in its initial review, the rule largely maintains the status quo on ASC policy, with one significant exception: the continued phaseout of the inpatient-only (IPO) list.
What follows is a look at what the proposals mean for the way centers actually run: where the payment update lands once you get past the average, what the next round of higher-acuity procedures asks of a center that takes them on, and where the seemingly quieter parts of the rule still carry some weight.
CMS is continuing the three-year phaseout of the IPO list it began in 2026. According to the agency's fact sheet, the 2027 rule proposes removing nearly 640 services from the IPO list across 11 clinical families, including digestive, urinary, respiratory, integumentary, endocrine, and male and female genital procedures. Alongside those removals, CMS proposes adding 618 codes to the ASC Covered Procedures List (ASC-CPL), most of which correspond to services that are leaving the IPO list. Taken together, the proposals would cut the IPO list roughly in half from the 1,438 services that remain under current policy.
For scale, the first year of the phaseout removed 285 procedures from the IPO list and added 271 to the ASC-CPL. The 2027 proposal more than doubles that pace, and the additions are more complex than last year's. Among the ones CMS names are procedures that, until recently, few would have likely expected to see in an ASC:
ASCA CEO Bill Prentice offered some perspective in the association's analysis, noting that the great majority of these procedures will still be done in hospitals for the foreseeable future, and that the change will "spark advancements in clinical care" that make more procedures available to patients in the lower-cost, more convenient outpatient setting.
CMS was candid about what it held back. The agency noted that most of the services still on the IPO list are more complicated and need a longer review before they come off in the final year of the phaseout. It pointed to procedures in the neurological and cardiovascular families, along with solid organ, intestinal, and islet cell transplants, as the kind of cases being saved for the 2028 rule. For centers, that's a useful signal about what is likely still to come, and a reason to get comfortable with this year's additions before the harder cases follow.
Taking on a case like a laparoscopic colectomy is a different undertaking than adding another cataract day. Before a center commits to the higher-acuity work now on the table, a few practical questions come up:
None of this is a reason to pass on the cases. It's the operational homework that comes with them, and it's easier to do before the first one is scheduled than after. SIS Complete keeps scheduling, clinical documentation, and the revenue cycle working from the same information, so a more complex case doesn't mean juggling separate tools to track it. On the documentation itself, SIS Scribe, our new AI-powered operative note solution, helps when a surgeon wants to dictate a fuller account of a complicated case. It captures the note accurately and finishes it quickly, so it doesn't sit open between the procedure and the claim.
CMS proposes an effective payment update of 2.4% for ASCs that meet quality reporting requirements, built from a 3.2% hospital market basket increase reduced by a 0.8 percentage point productivity adjustment. The agency again proposes updating ASC rates using the same market basket used for HOPDs. Extending an alignment, ASCA had asked CMS to maintain across all covered procedures, CMS estimates the update represents roughly a $520 million increase, bringing projected total Medicare payments to ASCs to about $9.9 billion for 2027.
The 2.4% is an average, and it hides a lot. CMS projects that changes will vary widely by specialty, with some seeing increases as large as 35% and others facing decreases of up to 4%. ASCA's initial analysis put it plainly: all 10 of the top ASC codes by volume are projected to be reimbursed below their 2026 rates. Those codes sit in ophthalmology, gastroenterology, and pain management, among the highest-volume work ASCs perform. The reductions are small per case, but they apply to the procedures a typical center bills most often.
ASCA President Todd Currier made the same point in the association's initial observations on the rule, noting that while the association was gratified to see ASC updates kept aligned with HOPDs, other payment policies could discourage ASCs from caring for Medicare beneficiaries because the proposal would actually reduce payments for the most common procedures ASCs perform.
For most centers, this is the part of the rule to watch. A one or two percent cut on a single case may not seem like much. But on a code a center runs dozens of times a week, it adds up quickly. And most centers are already losing some of that money before the rate ever changes, through claims that go out undercoded, denials that never get reworked, and charges that slip past capture. When the underlying rate ticks down, those everyday misses cost a little more than they used to. The most dependable way to offset a rate cut is to collect fully on the cases a center already runs, which means getting the coding right, capturing the charges, and working denials rather than writing them off. SIS Revenue Cycle Services focuses on exactly that work, on the high-frequency procedures where small losses pile up fastest.
On quality reporting, the 2027 rule does not move much. The one notable change is the proposed removal of ASC-9, the measure that checks whether a recommended 10-year follow-up interval is documented after a normal colonoscopy in an average-risk patient. The removal would begin with the CY 2027 reporting period, affecting the CY 2029 payment determination. CMS's reasoning is that the measure tracks whether the interval was written down, not whether the patient actually returned, and a separate colonoscopy measure already gets closer to a real outcome. CMS proposes no new measures for the ASCQR Program this year.
CMS is also asking for input on stratifying the All-Cause Hospital Transfer/Admission measure by phase of care — pre-procedure, intra-procedure, and post-procedure — to make the measure more useful. It's a small ask today, but it lines up with the rest of the rule. As centers take on more complex cases, how quality gets measured will need to account for which patients and which phases of care carry more risk.
A year with no new measures to chase leaves a little room to breathe, and that room is worth spending before the case mix gets even more complex. The documentation and data-capture habits that harder cases rely on are easier to build now than under pressure later, and they point in the same direction CMS is signaling with the stratification request. SIS Comply helps ASCs keep credentialing and compliance organized as centers add more complex cases, which turns a quiet reporting year into a chance to catch up or hopefully get ahead.
The comment period on CMS-1850-P runs through August 31, so centers with a view on the payment methodology or the pace of the IPO phaseout have time to weigh in directly or through ASCA. The planning does not need to wait for the final rule, which is likely to publish around Thanksgiving. The proposals point in a clear enough direction: more complex procedures are becoming available in the ASC, and reimbursement for everyday cases is under some pressure. Both are manageable, and the centers that get ready ahead of time will have an easier go of it.
Getting ready tends to come down to three things:
The centers that handle regulatory change well are usually the ones whose systems were already in good shape before the change arrived.
ASCA has consistently made the case that the ASC model saves Medicare money, pointing to a commissioned study projecting nearly $85 billion in Medicare savings over the next decade because ASCs are a lower-cost site of care. The 2027 rule moves more of that care into the ASC. Whether a center captures the opportunity comes down to how well its operations are set up to handle it.
The 2027 proposed rule brings more opportunity into the ASC along with a few more things to manage. Bigger cases raise what's required of documentation and compliance, and the rate changes make revenue cycle accuracy matter more on everyday work. SIS Complete, SIS Scribe, SIS Revenue Cycle Services, and SIS Comply are built to help centers handle both without adding to the daily workload. SIS has spent three decades working alongside ASCs to help them Operate Smart™. To see what that looks like for your center, request a demo.
CMS proposes an effective update of 2.4% for ASCs that meet quality reporting requirements, based on a 3.2% hospital market basket increase reduced by a 0.8 percentage point productivity adjustment. This is an average across all covered procedures, and CMS projects the actual change to vary significantly by specialty and code. All 10 of the highest-volume ASC codes are projected to be reimbursed below their 2026 rates.
What procedures are being added to the ASC Covered Procedure List for 2027?CMS proposes adding 618 codes to the ASC-CPL, most corresponding to services being removed from the inpatient-only list. Notable additions include laparoscopic colectomy, partial kidney removal, sleeve lobectomy, and prostate-removal surgery. These represent a meaningful step up in clinical complexity compared with the procedures added in the first year of the phaseout.
Is the ASC-9 quality measure being removed?Yes. CMS proposes removing ASC-9, the appropriate follow-up interval measure for normal colonoscopy in average-risk patients, beginning with the CY 2027 reporting period, which affects the CY 2029 payment determination. CMS notes the measure tracks whether a follow-up interval was documented rather than whether the follow-up occurred, and that a separate measure tied more closely to clinical outcomes already exists. No new ASCQR measures are proposed for 2027.
When are comments due on the 2027 proposed rule?Comments are due Aug. 31, 2026. CMS is expected to publish the final rule later in the year, with policies generally taking effect Jan. 1, 2027.