CMS CY27 Proposed Rule Takes: Home Health, OPPS, ASC, Imaging Site Neutral

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CMS CY27 Proposed Rule Takes: Home Health, OPPS, ASC, Imaging Site Neutral

USA | Healthcare Services EquityJulyResearch5, 2026

CMS CY27 Proposed Rule Takes: Home Health,

OPPS, ASC, Imaging Site Neutral

CMS's CY27 proposed rules were modestly better than expected, with a ~2.4%

net rate increase for home health (ADUS, AVAH, BTSG, PNTG) and a similar

update for HOPDs/ASCs, supporting HCA, THC, CYH, and SGRY. Importantly,

CMS continues to advance the long-term shift of care toward lower-cost

settings through further reductions to the inpatient only list and targeted

site-neutral imaging reimbursement, reinforcing favorable outpatient and ASC

volume trends.

CMS Proposes CY27 Home Nursing Rate of +2.4%. That Includes Expected PDGM Cut and

Market Basket Update.

The CY27 home health rule proposes a +2.4% update, which includes a +3.1% market basket•

update, offset by a -1.0% productivity adjustment and a +0.3% adjustment related to outlier

payments.

Importantly, CMS's temporary CY26 PDGM recoupment does not carry forward into the CY27•

rate-setting methodology, effectively resetting the baseline and adding back ~3% before

annual updates are applied. After incorporating market basket, wage index, and case-mix

adjustments, rates would be up ~5.8% vs CY26 prior to the proposed 3.0% PDGM behavioral

adjustment. While the proposed PDGM cut remains a meaningful headwind relative to an

otherwise ~6% update, we believe investor concerns around a stacked negative rate impact

(-0.6%) are overstated.

Looking ahead, there could be modest upside to the final rule if market basket assumptions•

move higher, though we are less convinced CMS will materially soften the proposed PDGM

adjustment given the proposal still produces a positive net update.