What’s in the CMS 2026 OPPS and ASC Final Rule?

In late November 2025, CMS released the 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Final Rule. Key proposed changes, which we previously covered here, included the potential adoption of the Information Transfer PRO-PM for ASC quality reporting (ASCQR), the phased elimination of the Inpatient-Only List (IPO), a substantial expansion of the ASC Covered Procedures List (CPL), and consideration of new payment pathways for Software as a Service (SaaS) solutions.

Below is a summary of some of the most critical updates in the final rule, which can be found in its entirety in the Federal Register.

Information Transfer PRO-PM Not Finalized for ASCs

CMS had previously proposed adding the Information Transfer patient reported outcome based performance measure (PRO-PM) into the ASCQR. Focused on capturing patient feedback on how well care teams communicated and coordinated information during care transitions, the Information Transfer PRO-PM is already mandated in quality reporting for hospital outpatient departments, as well as in years 3-5 of the Transforming Episode Accountability Model (TEAM).

In this final rule, CMS opted not to include this measure in the ASCQR for 2026 primarily due to feedback from stakeholders on the proposed rule, including: 

• Survey fatigue and low response rates: Acknowledging the risk of low response rates and research citing existing survey fatigue leading to lower response rates in the OAS CAHPS survey, CMS recognized that including a new survey may jeopardize data quality and increase care team burdens. In addition, it was noted that many patients undergoing same-day low-risk procedures may be less motivated to complete multiple surveys.
• Administrative burdens on ASCs: Considering the smaller size of administrative teams at ASCs, managing multiple surveys would be far more challenging and may lead to undue burdens.
• Lack of testing surrounding usage in the ASC setting: Some feedback focused on how the Information Transfer PRO-PM has not been tested in ASCs and that modifications would be required to align the survey with usage in ASCs.
• Challenging anonymity requirements: Given that the language in the Information Transfer PRO-PM indicates that patient anonymity must be maintained, CMS received many comments noting that this would make it very difficult for both hospitals and vendors to administer the survey reliably. CMS acknowledged that the language used can be confusing and noted that it will consider introducing changes and detailed guidelines on how protected health information (PHI) can be narrowly used to enable survey administration while maintaining patient anonymity.

While the Information Transfer PRO-PM is not moving forward for ASCs in 2026, CMS emphasized ongoing interest in using PROMs, PRO-PMs, patient experience metrics, and episode-level accountability across care settings, signaling that future iterations of similar PROM-based metrics are possible.

IPO List Phasing Out by 2028

One major proposal CMS finalized was the phased elimination of the IPO, which will unfold over the next three years. Beginning in 2026, CMS will remove 285 mostly musculoskeletal procedures, plus a subset of previously delisted services. Once removed, procedures become eligible for payment in either inpatient or outpatient settings, based on physician judgment. In addition, CMS reaffirmed that newly removed procedures would remain exempt from Two-Midnight Rule reviews until a majority of procedure volumes shifts to the outpatient setting.

As more procedures become eligible for performance in outpatient settings, hospitals and ASCs must update several operational areas, including site of service workflows, physician documentation, medical-necessity training, scheduling and pre-authorization processes, and patient liability communications.

These changes are essential because outpatient surgery places greater emphasis on effective patient engagement, consistent discharge readiness, and close monitoring of post-operative recovery. In this environment, patient-reported outcomes and functional measures become key tools for assessing quality and identifying when patients need additional support.

ASC Covered Procedures List to Expand

Another major update from this final rule is the substantial expansion of the ASC CPL. CMS finalized the removal of five exclusion criteria, granting clinicians greater discretion to determine ASC suitability. This update expands the CPL with 560 new surgical procedures (including those removed from the IPO list) as well as 35 new ancillary services.

This is a clear signal of CMS’s intent to expand access to lower-cost surgical settings, increase consistent treatment of different sites of service, and give physicians more control over where they provide care.

As eligibility for outpatient procedures increases, outpatient care leaders should prepare for increased volume and complexity of procedures. With this shift, it becomes necessary to be well prepared for more diverse patient populations with variable risk profiles, which requires improved pre-op preparation and post-op follow-up and a need for consistent patient education across surgeons and specialties throughout the episode of care.

SaaS Payment: No New Pathway for 2026

Many stakeholders hoped CMS would finalize a clearer payment model for digital health solutions and SaaS offerings. Instead, CMS determined that current OPPS pathways will remain in place for 2026. This decision reflects the wide variation in how digital health tools operate today as well as the limited standardized cost data available across these services. As a result, digital solutions will continue to be billed through existing mechanisms for now.

Even without SaaS payment policies, organizations still face strong incentives to adopt digital care management tools to strengthen quality reporting, support value-based care initiatives, reduce costly adverse events, and improve PROMs and PRO-PM readiness.

How Force Therapeutics Helps You Stay Ready

The CMS 2026 OPPS and ASC final rule underscores the ongoing shift toward expanded outpatient care options, increased physician autonomy, and a stronger emphasis on incorporating patient voices into quality assessment.

As more higher acuity procedures are performed in the outpatient setting, care quality, remote monitoring, digital education, and care coordination become a necessity to ensure strong patient outcomes and high patient satisfaction. Force Therapeutics helps hospitals and ASCs adapt to the shifting landscape by automating PROMs collection, patient education, remote monitoring, and patient engagement, allowing care teams to focus their time on patient care instead of paperwork.

Learn how it works. Book a demo today: