LUGPA Policy Alert: LUGPA Comments on CY 2027 OPPS/ASC Proposed Rule

September 2026

At a Glance

In late August, LUGPA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS-1850-P).

The proposed rule includes several policies important to independent urology, including 340B drug payment reform, ASC reimbursement, site-neutral payment, innovative urologic technologies, and expansion of ASC-eligible procedures.

LUGPA supports policies that promote high-quality care in the most clinically appropriate and cost-effective setting, while urging CMS to ensure payment policies do not disadvantage independent practices and ASCs.

Key Takeaways

340B Payment Reform

LUGPA supports CMS’s proposal to change payment for 340B-acquired drugs from ASP +6% to ASP -33.4%, based on acquisition-cost data.

LUGPA believes this would reduce payment distortions that can encourage hospital acquisition of physician practices and outpatient facilities. LUGPA also urged CMS to address 340B incentives associated with off-campus provider-based departments and future acquisitions.

ASC Payment

LUGPA is concerned that proposed changes could significantly reduce ASC reimbursement. CMS estimates that 85 of the top 100 ASC codes by volume would see payment decreases in 2027. LUGPA urged CMS to eliminate the ASC weight scalar or adopt an alternative that does not systematically disadvantage ASCs.

If ASC payment continues to decline relative to hospital outpatient payment, procedures could shift to higher-cost hospital settings, increasing costs for Medicare and patients.

Innovative Urologic Care

LUGPA urged CMS to ensure payment accurately reflects the resources required for new technologies, including CPT 52282 and CPT 55882.

LUGPA supports CMS’s proposed APC reassignment for CPT 52282 but believes it should receive device-intensive status to better account for permanent urethral stent costs. For CPT 55882, LUGPA is concerned the proposed device-offset reduction could result in an approximately 37% payment reduction in the ASC setting.

Site-Neutral Payment

LUGPA supports CMS’s proposal to apply MPFS-equivalent rates to certain imaging services furnished in excepted off-campus provider-based departments and encouraged CMS to expand site-neutral payment to additional services, including imaging with contrast.

LUGPA believes site-neutral payment can reduce incentives for hospital ownership and encourage care in lower-cost settings.

Expanding ASC-Eligible Urologic Care

LUGPA supports CMS’s proposed removal of appropriate urologic services from the Inpatient Only (IPO) List and expansion of the ASC Covered Procedure List.

Moving appropriate procedures to ASCs can improve patient convenience, reduce costs, and expand access to efficient physician-led care—provided Medicare payment adequately reflects the resources required.

LUGPA’s Recommendations

LUGPA urged CMS to:

• Finalize 340B payment reform and address incentives that contribute to consolidation.
• Eliminate or reform the ASC weight scalar to prevent systematic reimbursement reductions.
• Ensure adequate payment for innovative urologic technologies and high-cost devices.
• Expand site-neutral payment to reduce incentives for hospital ownership and higher-cost care.
• Continue moving appropriate procedures from inpatient to outpatient and ASC settings.
• Use supplemental cost information when claims data do not accurately reflect the cost of emerging technologies.
• Maintain payment policies that support independent practices and efficient sites of care.

The Bottom Line

Medicare policy should reward efficient, high-quality care—not ownership of the site where care is delivered.

LUGPA supports modernizing the OPPS and ASC payment systems while ensuring reforms protect independent practice, strengthen ASCs, encourage innovation, reduce consolidation incentives, and preserve patient access to physician-led urologic care.