On July 7, 2026, CMS published its proposed rule for the CY 2027 Hospital Outpatient (OPPS) and Ambulatory Surgical Center payment systems (CMS-1850-P). Comments are due approximately 60 days after publication, with a final rule expected in November 2026. Because commercial payers commonly benchmark ASC contracts to Medicare, these proposals will shape both Medicare and private reimbursement. Here is what matters for interventional pain practices operating in the ASC setting.
THE GOOD: Neuromodulation and device-based procedures win big
CMS proposes a 2.4% ASC update, raising the conversion factor from $56.322 to $57.766, and retains the more favorable hospital market basket through 2027. The nervous-system and musculoskeletal specialty groups — home to nearly all IPM codes — each gain +6%, the strongest in the ASC program. Prior authorization for facet injections, facet RF ablation, SCS lead implants, and (starting July 2027) an expanded botulinum toxin list applies only to hospital outpatient departments, not ASCs — making the ASC the faster and better-paid site of service. CMS also proposes adding 618 procedures to the ASC Covered Procedures List.
THE BAD: Bread-and-butter injections keep eroding
Despite the +2.4% system update, epidural injections, facet injections, and facet RF ablation all decline — losing ground to inflation for another year. Office-based payment caps continue to suppress ASC facility fees for many injection codes, and these relative-weight cuts compound annually.
THE UGLY: Cliffs and penalties to plan for
- Non-opioid payment cliff: the temporary separate payment for qualifying non-opioid pain treatments (e.g., liposomal bupivacaine) expires December 31, 2027 unless Congress acts.
- Quality-reporting penalty: ASCs failing ASC Quality Reporting receive only a 0.4% update — a 2-point penalty worth roughly 2% of all Medicare revenue.
Proposed CY 2027 changes — key IPM codes
| Code | Procedure | Proposed Changes from the 2026 Payment Rates |
|---|---|---|
| 63685 | SCS generator insertion/replacement | +14.8% |
| 64555 | PNS electrode implant | +9.8% |
| 64561 / 64590 | Sacral electrode / pulse generator | +8.0% |
| 64628 | Basivertebral nerve ablation | +6.5% |
| 27279 | Minimally invasive SI joint fusion | +7.1% |
| 63650 | Percutaneous SCS lead implant | +6.2% |
| 62323 | Interlaminar ESI, lumbar/sacral | −3.8% |
| 64483 | Transforaminal ESI, lumbar/sacral, first level | −3.8% |
| 64493 | Lumbar/sacral facet injection, first level | −3.8% |
| 64635 | Lumbar facet RF ablation, single joint | −4.3% |
Five action items
- Protect your ASCQR quality-reporting status — the 2-point penalty is the single largest controllable payment variable.
- Grow the neuromodulation line — SCS, PNS, and sacral stimulation carry the strongest payment trajectory; evaluate adding SI joint fusion and basivertebral nerve ablation.
- Plan for the non-opioid payment sunset — budget for 2028 if your practice relies on qualifying products.
- Submit comments — injection-code cuts compound annually. ASIPP will coordinate comments; watch for our call to action.
- Revisit commercial contracts — consider fixed-year Medicare benchmarks or rate floors, carve-outs for high-cost implants, separate non-opioid product payment, and explicit exemption of ASC claims from hospital outpatient prior-auth policies.
Code-level proposed rates appear in Addenda AA and BB on the CMS website, not in the rule itself. These are proposals — verify all figures against the final rule before making financial projections. This summary is informational and is not legal or reimbursement advice.
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