Proposed rule — comments on the OPPS/ASC rule close August 31, 2026. File on docket CMS-2026-2344 →
CY2027 proposed rules · read from the primary
CY2027 is a scissors,
not a cut.
CMS proposes to reduce the work RVUs on hip and knee replacement roughly 20 percent — largely because the case already moved outpatient. The value does not disappear. It reappears on the facility line at +2.4 percent.
Whether you keep it depends on whether you own the building.
−20%
work RVUs, 27130 / 27447
Proposed cut to the work RVUs on hip and knee replacement — roughly 3× the ortho specialty average. In the PFS rule, not this one.
CMS-1848-P →
+2.4%
OPPS and ASC facility rates
The same proposed update on both facility systems. ASC total payments rise about $520M to roughly $9.9B.
CMS-1850-P →
Aug 31
2026 — comments close
The OPPS/ASC comment window. The PFS rule closes separately on September 14.
Docket CMS-2026-2344 →
Jan 1, 2029
inpatient-only list is gone
1,438 services remain today. CY2027 proposes removing 637 of them; CY2028 takes the rest.
CMS OPPS notices →
The mechanism nobody prices in
The professional cut and the facility raise are not two unrelated line items. They are one movement, and it runs in a specific order.
01
The case leaves the inpatient-only list
Total joints came off years ago — knee in 2018, hip in 2020. The procedure migrates to the hospital outpatient department or the ASC.
02
A site-of-service screen flags the professional code
Once the case is routinely done outpatient, the valuation of the professional work gets re-examined against the new setting.
03
The work RVUs come down
CMS accepted the RUC recommendation to cut work RVUs on 27130 and 27447 roughly 20%. AAHKS and AAOS have filed against it.
04
The facility line goes up 2.4%
The value did not evaporate. It moved across the bill. Whoever owns the facility collects it; a surgeon with no ownership simply absorbs the professional cut.
And it is recurring, not a one-time event.
The screen marches down the migration list. Hip and knee are simply the codes that migrated first and carry the most volume. Shoulder and spine sit behind them on the same path — the CY2026 rule already moved lumbar fusion (22630, 22633) onto the ASC-covered list. Anything that leaves the inpatient-only list eventually gets its professional valuation re-examined in the setting it moved to.
Model your own exposure
Every assumption is on screen and editable. This models the proposed rules at your own numbers — it is not a fee-schedule lookup, and it is not advice.
Your yearly primary arthroplasty volume under Medicare.
Part B professional payment only — not the facility side.
The cut applies to work RVUs, which are only part of the payment. Typically around 55% for major arthroplasty — check your own fee schedule.
Enter your volume and payment, then model it. The output shows the professional exposure, what the facility side recaptures, and the net — which is the number that actually changes based on ownership.
Modeled from the proposed CY2027 rules, not a fee-schedule lookup. Both rules are proposed and may change before they are finalized. Your actual payment depends on your locality, your payer mix, the final conversion factor, and the final RVUs. Verify against your own schedule before you act on it.
CY2027 is not orthopedics’ year — and that is the point
The headline making the rounds is “618 codes added to the ASC list, 637 off inpatient-only.” Both numbers are real. Neither one is about your panel.
They are the same procedures
The rule proposes to add 618 procedures to the ASC covered list precisely because it proposes to remove them from inpatient-only. It is one migration counted twice, not two separate expansions.
Read the rule text →
Musculoskeletal is not on the list
The CY2027 removals come from eleven clinical families: auditory, digestive, endocrine, female genital, hemic and lymphatic, integumentary, male genital, maternity care and delivery, mediastinum and diaphragm, respiratory, and urinary. Ortho is in none of them.
ASC covered-list addenda →
Because you already went
Knee replacement came off inpatient-only in 2018, hip in 2020. Orthopedics is not waiting for this migration. It is the precedent everyone else is now following — and the professional revaluation is what came after.
OPPS rule history →
If someone tells you 618 new codes just opened up for your panel, they did not read the rule. What actually matters to an orthopedic practice in this document is the facility update, the pace of the inpatient-only phase-out — 1,438 services remain, about half proposed to go in CY2027, the rest in CY2028, the list eliminated entirely on January 1, 2029 — and what all of that implies for who owns the room your cases are done in.
Two forces you should price separately
PRICE — WORKING AGAINST YOU
The leverage gap no negotiation closes
On commercial contracts, hospital outpatient departments are paid roughly 278 percent of Medicare while independent ASCs get about 171 percent. RAND’s work attributes most of that variation to hospital market power, not quality. Under Medicare, the ASC conversion factor sits near 62 percent of the hospital outpatient rate. The +2.4 percent lands on a structurally lower base.
RAND price transparency research →
VOLUME — WORKING FOR YOU
The cases are being steered your way
In March 2026 the Department of Justice sued NewYork-Presbyterian in the Southern District of New York under Section 1 of the Sherman Act over contract terms that blocked insurers from steering patients to lower-cost sites including ASCs. Site-of-care steering is now a federal antitrust priority, and commercial payers have moved the same direction with site-of-service policies.
DOJ Antitrust Division →
Put together: hospitals keep the per-case price premium, but they are losing the volume. An independent ASC takes a lower price per case and a rising, payer-directed share of the cases. That makes this a volume argument, not a rate argument — which means your two real levers are cost per case and patient demand, not the contract you were never going to win.
Two things are still inside your control
You cannot vote the RVU back by yourself. These are the moves that remain before January 1.
BY AUGUST 31, 2026
Comment on the record
The OPPS/ASC docket is open to anyone. Specialty societies are filing on the arthroplasty revaluation in the companion PFS rule, which closes September 14. A comment from a surgeon who does the case carries a different weight than one from a trade association.
Docket CMS-2026-2344 →
EVERY DAY BETWEEN NOW AND THEN
Capture what the current schedule already owes you
A proposed cut you cannot control is a bad reason to keep leaving money on a schedule you can. Wonder Bill reads an operative note and finds the codes that were supported and not billed.
Run a note through Wonder Bill →
THE LONGER ARC
Where the episode economics go next
If the value keeps moving from the professional line to the facility and episode side, the practices that hold up are the ones that can carry an episode. See how the rest of the payment stack lines up.
SurgeonValue economics →
READ FROM THE PRIMARY
CMS-1850-P — OPPS/ASC CY2027
91 FR 41734, July 7, 2026. The facility rule: +2.4%, the 637 inpatient-only removals, the 618 ASC additions.
CMS-1848-P — PFS CY2027
The companion physician rule. The arthroplasty work-RVU revaluation lives here, not in the OPPS rule. Comments close September 14.
Comment docket CMS-2026-2344
Where OPPS/ASC comments are filed. Closes August 31, 2026.
ASC payment addenda
The covered-procedures and payment-indicator addenda are published on the CMS website, not in the Federal Register text.