CMS Releases Proposed Rule for 2026 Hospital Outpatient Payment System

On July 15, the Centers for Medicare & Medicaid Services (CMS) released the 2026 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule. Following are a few key points that the rule addresses. Stay tuned to ASNC for additional analysis of the proposed policies.

Hospital Outpatient Update

CMS is proposing a 2.4 percent update to HOPPS payment rates. This increase is based on the projected hospital market basket increase of 3.2 percent reduced by a 0.8 percentage point productivity adjustment.

Packaging for Diagnostic Radiopharmaceuticals

In 2025, CMS finalized a change in how it pays for diagnostic radiopharmaceuticals. CMS reformed its packaging policy and began paying separately for any diagnostic radiopharmaceutical with a per-day cost greater than $630 and removing the costs of such radiopharmaceuticals from the payments for nuclear medicine tests.

For 2026, CMS proposes to update the $630 cost-per-day threshold using Producer Price Index levels for Human Use, Prescription data, from the Bureau of Labor Statistics, which would result in a payment threshold of $655 cost per day. This means that, in 2026, radiopharmaceuticals costing over $655 per day would be paid separately from the service in which they are used.

Radiopharmaceuticals with a per-day cost below the $655 threshold would remain packaged with the services in which they are used. This would include many radiopharmaceuticals used in SPECT and cardiac PET procedures.

The diagnostic radiopharmaceuticals that exceed the $655 per-day cost threshold would be assigned to an ambulatory payment classification, making them specified covered outpatient drugs. For 2026, CMS is proposing to continue paying separately for radiopharmaceuticals over the threshold based on their arithmetic mean unit cost, which would be based on 2024 claims data. CMS says it must have more consistent, validated reporting to use other methodologies, such as average sales price.

In the coming weeks, ASNC will share additional analysis on this proposal as it relates to nuclear cardiology services.

Software as a Service

CMS continues efforts to address reimbursement methodologies for software as a service (SaaS), meaning software-based technologies that support clinical decision making. The agency is soliciting feedback from the public on how the value of such technology may be adequately weighed and recognized in CMS payment policy. CMS requests feedback for both hospital outpatient and physician office settings.

Add-on Payment for Technetium-99m (Tc-99m) Derived from Domestically Produced Molybdenum-99 (Mo-99)

CMS is proposing to continue the $10 per-dose add-on payment for domestic sources of Mo-99. CMS proposes to define domestically sourced Mo-99. At least 50 percent of the Mo-99 used in the Tc-99m generator that produced a dose of Tc-99m must have been domestically produced to qualify for the additional payment. The new add-on code would be HCPCS code C917X (Tc-99m from domestically produced non-HEU Mo-99, [minimum 50 percent], full cost recovery add-on, per study dose).

More Details Coming

ASNC will submit comments to CMS in response to these and other proposals.

For background, please refer to the following documents:

• 2026 Hospital Outpatient Prospective Payment System Proposed Rule
• 2026 Hospital Outpatient Prospective Payment System Proposed Rule Fact Sheet

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