Lexology January 13, 2026
Nelson Mullins Riley & Scarborough LLP

Washington policymakers are increasingly aligned around expanding Medicare “site-neutral” payment policies in 2026, a shift that would pay hospital outpatient departments the same rates as physician offices for a broader set of common services.

Regulatory Developments

In November, CMS finalized a policy to align Medicare payments for certain drugs administered in physician offices and hospital outpatient departments beginning in 2026. CMS estimates that similar site-neutral payment adjustments could generate more than $6 billion in federal savings over 10 years, based on prior CBO analyses.

CMS has also signaled that additional services could be targeted in future rulemaking. In a proposed payment rule released in July, the agency solicited public input on which services should be considered for expanded site-neutral payment...

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