2027 HOPPS Proposed Rule Would Restructure Nuclear Medicine APCs, Could Affect Nuclear Cardiology Payment Rates

In the 2027 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule, the Centers for Medicare & Medicaid Services (CMS) proposes reorganizing the Nuclear Medicine and Related Services ambulatory payment classification (APC) series (5591-5594). If finalized, the policy would move the PET/CT code family currently assigned to the New Technology APCs to the top tier of the nuclear medicine APC series (5594).

Following release of the HOPPS proposed rule, ASNC compiled a reimbursement chart showing the rates that would result from CMS’s proposed APC reorganization.

View the proposed rates for nuclear cardiology services in ASNC’s HOPPS reimbursement chart.

The chart showed proposed rates for nuclear cardiology services ranging from 4% to 15% higher than 2026 rates. It is important to note that these proposed rates reflect not only the APC reorganization but also another policy in the proposed rule that would change CMS reimbursement for 340B drugs.

340B Policy Could Affect Proposed Payment Increases

CMS is proposing to reduce payment for 340B drugs from the average sales price (ASP) plus 6% to the ASP minus 33.4%. If finalized, the change would reduce Medicare spending on 340B drugs by an estimated $4.85 billion in 2027. Federal law requires that CMS maintain budget neutrality within the HOPPS. Thus, CMS proposes an 8.44% increase in reimbursement for non-drug outpatient services covered under the HOPPS, which CMS estimates would offset cuts to 340B drug spending in 2027. This means that, if the 340B drug policy is finalized, then the 8.44% upward adjustment will remain in 2027 reimbursement rates. However, if the 340B drug policy is not finalized, then that upward adjustment will not be included in 2027’s reimbursement rates.

Last week, ASNC submitted comments to CMS on the HOPPS proposed rule. In addition to expressing support for the proposed reorganization of the Nuclear Medicine and Related Services APCs, ASNC commented on proposed payments for diagnostic radiopharmaceuticals, expansion of site-neutral payment policies, and software-as-a-medical-service diagnostic services.

CMS is expected to release the 2027 HOPPS final rule in November. Stay tuned to ASNC for news and analysis of CMS’s final policies affecting nuclear cardiology.

Get Details at ASNC2026

ASNC Director of Regulatory Affairs Georgia Lawrence, JD, will address the potential implications of the HOPPS proposal during the ASNC2026 session Billing, Compliance, and the Future of Nuclear Cardiology Reimbursement.

Moderated by Preeti Kansal, MD, and Friederike Keating, MD, FASNC, the session will also cover how evolving billing policies could affect reimbursement for SPECT, PET/CT, and PET; strategies for improving coding accuracy; and supervision and billing requirements when expanding into new services. The session will be held Friday, Sept. 18, at 1:30 PM (Pacific Time). Choose in-person or virtual attendance.

Register for ASNC2026