2026 OPPS Proposed Rule: The ASC Gold Rush Is About to Begin

The dust has barely settled on CMS's 7/14 announcement of the 2026 OPPS Proposed Rule, but the implications are clear. This represents a complete reshuffling of the outpatient surgery landscape that device companies need to understand immediately.

If this is a TL;DR and you’re just looking for the list of CPT and HCPCS codes that will be eligible for ASCs… we put them all in a spreadsheet for you. You can CTRL+F the code or procedure name you’re looking for, but feel free to snuggle up on the couch and read through all 500+.

--> Full Code List

The Great ASC Migration

Two policy changes are about to create the largest shift of procedures from hospitals to ASCs we've seen in years.

While this rule technically only affects Medicare payments, the ripple effects go much wider. Commercial payers often follow Medicare's coverage decisions, and ASCs won't invest in new service lines unless multiple payers reimburse for them. When Medicare signals these procedures are appropriate for ASCs, it opens the door for broader market adoption across all payer types.

First, the inpatient-only list is getting the axe over the next three years. CMS is eliminating 285 procedures from the Inpatient-Only (IPO) list in 2026, with most being musculoskeletal procedures. 

Translation: Many surgeries that could only happen in hospital inpatient settings can now be performed in outpatient facilities, including ASCs.

But there's more. ASCs are actually getting a total of 547 procedures added to their covered list. The breakdown: 276 newly approved procedures, plus 271 of those procedures breaking free from the IPO list.

For device companies, this creates an entirely new addressable market. Those orthopedic implants that could only be used in hospital inpatient departments? Now they can be sold to ASCs too. The market just got a lot bigger overnight.

But ASCs operate differently than hospitals. They're cost-conscious, efficiency-focused, and they make purchasing decisions based on different criteria. Sales teams that have been calling on hospital buyers for years will need to recalibrate their approach. And if they haven’t targeted ASCs before, they may not have a good grasp of who to target first.

Skin Substitute Reimbursement

If you're in the wound care or dermatology space, pay attention. CMS is "unpackaging" skin substitute products from their application procedures, moving skin substitutes from being reimbursed as expensive biologicals under ASP+6%, to being treated as "incident‑to" supplies. This ends a policy that's been in place since 2014.

The old way: Hospitals received one bundled payment covering both the procedure and the product, regardless of cost differences between a basic dressing and a premium biologic.

‍The new way: Hospitals get separate payments for the procedure AND the product. Initially, one rate covers all. but subsequent years might see differentiated rates with payment amounts tied to FDA regulatory categories (361 HCT/P, PMAs, and 510(k)s).

What device companies need to do now

Map your ASC opportunity:
If your products are used in procedures recently approved for ASCs, you've got a new market segment to capture starting January 1, 2026.

Retool your sales approach:
ASCs make decisions faster but with different priorities than hospitals. They care about procedure efficiency, quick turnover, and predictable costs. Your value proposition needs to reflect this reality.

For wound care companies:
Sales reps will need to focus on clinical value and outcomes. Instead of selling based on ASP-driven margins, they'll need to demonstrate how the product performs within a flat reimbursement framework.
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The 2026 OPPS Proposed Rule isn't just about slightly increasing reimbursement rates (the American Hospital Association is big mad online). It's redrawing the entire outpatient surgery map. Companies that recognize this shift early and adapt their commercial strategies accordingly will capture the most value when these changes take effect in 2026.

The 60-day comment period is already underway, but the smart money says 95% of what’s in the proposed rule will make it into the final rule, so the time to prepare is now. 

Need help figuring out how to target the right ASCs? Give us a shout.

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