For years, healthcare economists have asked a simple question: why should Medicare pay substantially different amounts for the same service merely because one building has a hospital’s name on it?
CMS is increasingly turning that question into payment policy.

For 2027, CMS proposes expanding its method for controlling unnecessary outpatient volume at certain excepted off-campus hospital provider-based departments. The newest target is imaging without contrast. Under the proposal, qualifying HCPCS codes assigned to non-contrast imaging APCs would be paid at a Physician Fee Schedule-equivalent rate rather than the higher traditional OPPS amount when performed at those off-campus departments. Rural Sole Community Hospitals would be exempt.

This did not appear from nowhere. CMS began the policy with clinic visits. For 2026 it expanded the approach to drug-administration services. Now imaging is on the table. That progression matters because it demonstrates direction. CMS is not simply debating site neutrality in academic language. It is testing how far it can move reimbursement toward the proposition that location alone should not create a payment premium.

Independent surgery centers should understand the strategic implications. The hospital outpatient department has historically enjoyed a reimbursement advantage for many services while an ASC may deliver comparable care with a dramatically leaner cost structure. Every move toward site-neutral reimbursement weakens the economic value of the hospital label and increases the importance of actual efficiency.

That does not automatically mean more money for ASCs. In fact, site neutrality can eventually create pressure on everyone if policymakers decide that the lowest-cost appropriate setting should become the benchmark. But it does make one ASC characteristic increasingly valuable: we already know how to survive without hospital economics.

A well-run surgery center knows the cost of a surgical minute, the implant, the anesthesia coverage, the disposable pack and the nurse standing in the room. Hospitals have historically had more room for inefficiency.

That room is getting smaller.