We took a look at the recently proposed CMS ASC payment rule & graded it based on its possible impact.
Overall, the proposed rule earns CMS a C+ grade – better than anticipated. The proposal continues the trend toward appropriate site-of-service migration & gives ASCs new opportunities to participate in higher-acuity cases. However, it is not a blanket win for ASCs.
Some ASCs will be impacted more than others & no specialty will see any significant rate increases. Overall ASC provisions on quality, systems, documentation & enforcement are likely to have minimal impact as written.
ASC leaders should review the Section I Summary & the full list of impacted codes (Addenda AA & EE) paying special attention to their own high-volume codes.
Consider submitting comments to CMS before the August 31, 2026 deadline. Comments are an important opportunity to highlight how the proposed rule will affect real-world ASC operations, patient access, and physician decision-making.
Submit comments to CMS here: https://www.regulations.gov/document/CMS-2026-2344-0002
