Decoding the 2026 OPPS/ASC Proposed Rule: What CFOs Need to Know About Payment Shifts
Centers for Medicare & Medicaid Services (CMS) has published the 2026 Proposed Rule for the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Centers (ASCs). This rule indicates significant changes in how ASCs will be reimbursed and function. These initiatives create new revenue growth opportunities for agencies along with new operational issues. ASC CFOs and revenue cycle executives need to comprehend these proposals so they can adjust their financial plans and preserve margins for years beyond.
ASC Payment Rates: A Modest Increase with Strategic Implications
Under the proposed rule, Medicare ASC payment rates will rise by 2.4% in 2026 - matching the hospital outpatient rate increase. This stems from a 3.2% market basket update minus a 0.8% productivity adjustment.
On the surface, this is good. But inflation in medical supplies, personnel, and surgical devices has always outgrown reimbursement increases. The growth might stop further margin loss, but it won't necessarily generate new profits.
Key caveat: ASCs will only receive the full increase if they meet ASC Quality Reporting Program (ASCQR) requirements, a compliance area requiring consistent investment. Our best takeaway from the scenario is to build your 2026 budget using true cost projections, not just CMS's 2.4% rate. Align quality reporting compliance with operational efficiency to secure full payment eligibility.
Site-Neutral Payments: Shifting Competitive Dynamics
CMS keeps pushing site-neutral payment policies forward, narrowing the reimbursement difference between ASCs and hospital outpatient departments (HOPDs). Beginning in 2026, off-campus HOPD drug administration services will be paid 40% of OPPS rates, consistent with levels under the Physician Fee Schedule.
Though this affects hospitals more, it reinforces the ASC value proposition - higher-quality surgical care at a lower cost.
CFO takeaway: Leverage site-neutral policy changes in payer negotiations. Position your ASC as a cost-efficient, equally effective alternative for an expanded range of outpatient procedures.
Strategic Actions for ASC Leaders in 2026
1. Seize Growth from New Procedures
- Focus on high-margin cases that fit your existing clinical capabilities.
- Engage surgeons and care teams early to build smooth workflows for new service lines.
2. Preserve Margins Through ASC RCM Automation
- High-acuity cases mean more documentation, coding, and claims complexity.
- Use automated eligibility checks, coding validation, and claims scrubbing to maintain 95%+ clean claim rates. Plutus Health's ASC-focused RCM solutions are designed to support these goals.
3. Build Stronger Payer Relationships
- Leverage site-neutral policy changes as negotiation tools for better rates.
- Use measurable data - such as your ASC's safety record, efficiency metrics, and patient satisfaction scores to strengthen your position with commercial payers.
4. Optimize Quality Reporting and Compliance
- Meeting ASCQR requirements is essential to receive the full 2.4% rate increase in 2026.
- Implement processes that integrate quality reporting into daily operations to avoid compliance becoming an added burden. Plutus Health can streamline these reporting workflows within your revenue cycle.
5. Strengthen Financial Forecasting and Cost Control
- Model the financial impact of new procedures, staffing needs, and equipment investments before committing to service-line expansion.
- Track your cost-to-collect and A/R trends monthly to spot risks early and keep margins healthy.
As the 2026 OPPS/ASC Proposed Rule redefines the future of surgical care, success will come to ASCs that can embrace rapid change, grow smart, and maintain margins while performing increasingly complex, higher-value procedures. Plutus Health offers ASC-focused organizations exclusive RCM services, which combine automation, compliance know-how, and real-time analytics to enable CFOs to unlock the complete value of CMS's payment migration.
From prevention of denial to claims scrubbing and eligibility verification to clean claim optimization, our solutions are crafted to provide 95%+ clean claim rates, accelerated reimbursements, and improved payer relationships.
Schedule a No-Obligation Call with Plutus Health today and discover how we can future-proof your ASC's margins and operational efficiency in 2026.
Liked the blog? Share it
FAQs


ABA providers are grappling with high staff turnover (up to 65%), rising burnout, administrative overload, and stagnant reimbursement rates. These challenges directly impact care continuity, clinical outcomes, and operational performance.


Operational inefficiency costs ABA teams up to 10 hours per staff member per week, contributing to burnout, denied claims, and longer accounts receivable (A/R) cycles. These inefficiencies ultimately result in reduced revenue and patient dissatisfaction.


Burnout leads to costly turnover, lower client retention, and decreased productivity. Recruiting and replacing a BCBA or RBT can cost up to $5,000 per hire, plus months of lost revenue and disruption to morale.


High-performing ABA organizations invest in clear career pathways for BCBAs and RBTs, align compensation with market benchmarks, and foster peer-led mentorship, flexible schedules, and wellness programs.


Automation tools like Plutus Health's Zeus streamline eligibility verification, denial management, and billing, reducing manual workloads by 5–10 hours weekly per clinician and improving clean claim rates by 95%.


Outsourcing revenue cycle management can improve collections, reduce denials by up to 30%, and free clinicians from billing-related admin tasks, resulting in better client care and financial outcomes.


One $200 million ABA network partnered with Plutus Health to automate eligibility and accounts receivable (A/R) processes. The result: $2M reduction in legacy A/R and a 97% Net Collection Rate.


By improving operational efficiency, investing in technology, and ensuring workforce stability, ABA leaders can align outcomes with reimbursement. Plutus Health supports this transition with scalable RCM and automation strategies.
FAQs


ABA therapy billing is the process of submitting claims to insurance or Medicaid for Applied Behavior Analysis services provided to individuals with autism or developmental disorders. It includes using correct CPT codes, proper documentation, and adherence to payer-specific policies.


Common CPT codes for ABA therapy in 2025 include:
- 97151 – Assessment and treatment planning
- 97153 – Direct therapy with the patient
- 97155 – Supervision and modification of behavior plan
- 97156 – Family adaptive training
- Always check with payers for any annual changes.


To bill Medicaid for ABA services, providers must ensure credentialing is complete, services are pre-authorized, and claims use the correct codes and modifiers. Medicaid requirements vary by state, so always follow state-specific billing rules.


Common ABA billing mistakes include:
- Incorrect or missing CPT codesplan
- Lack of documentation or treatment
- Uncredentialed providers rendering services
- Submitting duplicate or late claims


Without proper credentialing, providers can’t get reimbursed. Insurance and Medicaid require that BCBAs, RBTs, and organizations are credentialed and contracted. Delays in credentialing often cause revenue losses and claim rejections.
FAQs


CMS proposes a 2.4% increase in Medicare ASC payment rates, contingent on meeting ASCQR quality reporting requirements. Plutus Health helps ASCs meet these compliance benchmarks by integrating quality reporting data into RCM workflows, ensuring eligibility for full payment updates.


The ASC Covered Procedures List will expand by 547 procedures, including cardiology, spine, and vascular surgeries. Plutus Health supports expansion into new service lines by customizing RCM processes for high-acuity procedures, minimizing claim denials during the transition.


Site-neutrality narrows the payment gap with hospital outpatient departments, enhancing ASCs' cost-efficiency appeal. Plutus Health helps leverage this advantage in payer negotiations by providing performance dashboards and cost-justification analytics to secure stronger reimbursement terms.


Complex procedures increase denial risk and slow cash flow. Plutus Health's automation-first RCM model delivers 95%+ clean claim rates, reduces A/R days, and safeguards margins, even as your case mix becomes more complex.