October 8, 2026
[RDNT, LMRI, Radiology Partners] CMS’s OPPS Imaging Site-Neutral Proposal Likely to Stick, Freestanding Imaging Still Poised to Benefit
Despite lopsided stakeholder opposition, we continue to expect CMS to finalize largely as initially sought its CY27 proposal cutting Medicare reimbursement for 337 common non-contrast imaging procedures at grandfathered off-campus hospital outpatient departments (HOPDs) while…
September 30, 2026
[Municipal Hospitals, HCA, THC, OPCH, CVS, MRK, PFE]: 340B Drug Reimbursement Expectations in the Final Medicare OPPS Rule
With CMS likely to release its final CY27 Medicare Hospital Outpatient Prospective Payment System (OPPS) rule in early November, we continue to expect a substantial cut to Medicare payment for 340B-acquired drugs administered in participating…
August 3, 2026
[HCA, THC, CYH, ARDT, UHS, Muni-backed] FY27 Inpatient Hospital Better Than Proposed but Medicare Payment Growth Slows
The FY27 Medicare inpatient hospital (IPPS) final rule was modestly more favorable than the proposal for acute care hospitals [HCA, THC, CYH, ARDT, UHS, MPT, muni-backed systems], increasing CMS’s projected aggregate payment increase by $1B….
July 2, 2026
Hospital/ASCs: Proposed 340B Rate Cut, Imaging Site Neutral and Outpatient Surgeries Inure Benefit to For-Profits While Hit to Nonprofits/Govt Hospitals
For-profit hospitals [THC, HCA, CYH, ARDT, UHS] received some expected positive news – though the magnitude surprised us – in the CMS’s proposed CY27 hospital outpatient prospective payment system (OPPS) rule. Ambulatory surgery centers (ASCs)…
June 10, 2026
Hospitals, ASCs, Imaging Centers: Medicare Risk in Summer OPPS Proposal? [THC, HCA, CYH, ARDT, UHS, SGRY, UNH, RDNT]
While Medicaid and ACA enrollment concerns have dominated the policy overhang for hospitals this year, Medicare-related risks could move higher on investors’ radar with the release of CY27 hospital outpatient prospective payment system (OPPS) proposed…
June 2, 2026
[CNC, MOH, ELV, HCA, THC, CYH] Medicaid Work Requirements: Deferment to States with Tighter Oversight in 2028; CMS Projects 15% Enrollment Decline
CMS’s long-awaited interim final rule implementing the One Big Beautiful Bill’s (OBBB) Medicaid Community Engagement (CE) requirements largely aligns with our expectations that CMS would defer to states on program design and implementation, which we…
May 18, 2026
Hospitals: Latest CMS Batch of Approved Hospital-Specific DPPs [HCA, CYH, THC]
Two long-anticipated hospital-specific Medicaid state directed payment programs (DPPs) in Florida and Indiana, benefitting HCA, CYH, and THC and other hospitals in those states, appear to have been approved by CMS in recent weeks, according…
April 12, 2026
Inpatient Hospitals: Slight Medicare Growth for FY27, But Future Holds Mandatory Bundles and Less Automatic Bonuses for New Tech [HCA, THC, CYH, ENSG, PACS, PNTG]
FY27 Medicare reimbursement proposals for inpatient hospitals [HCA, THC, CYH, ARDT, UHS, MPT, muni-backed systems] largely met expectations for a smaller increase, versus FY26, with most changes appearing formulaic and math-based rather than policy-led. Despite…
March 12, 2026
Hospitals: Latest CMS Batch of Approved Hospital-Specific DPPs [HCA, THC, UHS]
CMS’s latest approvals for hospital-specific Medicaid state directed payment programs (DPPs) provide incremental positive news for HCA, THC and UHS due to their footprint in certain states (Georgia, Michigan, Kentucky, and Nevada) where CMS recently…
February 23, 2026
Hospital DPPs: Less Dependable, Though Still Relevant Post-OBBB: Questions of Where and How Much Remain? [HCA, THC, CYH, ARDT, UHS, MPT, SGRY, govt hospitals]
While Medicaid funding from state directed payment programs (DPPs) cannot be relied upon as much a key revenue driver – and has received less attention on recent earnings calls – these incremental dollars are still…