CY 2027 OPPS & PFS Final Rules: What Device Teams Need to Do Now
Both CY 2027 final rules are out, effective January 1. OPPS leads: payments rise 2.3%, 637 services leave the Inpatient-Only list, 618 procedures join the ASC list, and SaMS gains a new payment home. What device teams need to do now.
Both CY 2027 final rules are out, effective January 1. For device companies, the hospital outpatient rule (CMS-1850-F) is the bigger story.
Site of care just shifted
CMS removed 637 more services from the Inpatient-Only list and added 618 procedures to the ASC Covered Procedures List. If your device was an inpatient story, your buyers, your evidence plan, and your price justification now have to work in outpatient departments and ASCs, where the economics are thinner and the scrutiny is sharper.
The rate picture
OPPS payments rise 2.3%, with a conversion factor of $99.970. Modest, but the packaging is what matters: check your APC assignment against the final rule, not the proposed one.
Software teams, take note
CMS renamed SaaS to Software as a Medical Service (SaMS) and assigned SaMS to New Technology APCs, and SaMS analyses of lab tests move from the lab fee schedule to OPPS payment. A new payment home means a new strategy.
Site-neutral pressure grows
Non-contrast imaging at off-campus provider-based departments now pays at the physician fee schedule rate, about $260M in first-year cuts. Where a service is performed matters more every year.
The Physician Fee Schedule still counts
The PFS conversion factor is $32.63 for non-QPs and $32.95 for QPs. The same-day E/M cut was finalized at 20%. G2211 has been replaced by modifier B1 (+16%), with a new modifier B2 (+32%) for ACOs.
What to do this quarter
Re-map your codes to the final APC and fee schedule assignments, rebuild site-of-care economics for outpatient and ASC settings, and revisit any forecast built on the proposed rules.
Book a complimentary consultation to walk through what the CY 2027 final rules mean for your device.
Unlock Market Access Success
