Establishing OPPS payment for IPO procedures: Challenges and methodological considerations

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The Centers for Medicare & Medicaid Services (CMS) recently finalized a policy to eliminate the inpatient only (IPO) list over a three-year period beginning in 2026, creating an immediate need to assign ambulatory payment classifications (APCs) and set Outpatient Prospective Payment System (OPPS) payment rates for a large volume of procedures with limited outpatient claims history.

A more transparent, data-driven approach could help reduce rate-setting uncertainty during the transition, and support clinically appropriate migration to lower-acuity settings without destabilizing reimbursement.

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