Comment Now on Medicare’s 2026 Proposed Rule

Digital Debut

Comment Now on Medicare’s 2026 Proposed Rule

Use ASCA resources to write your letter

BY KARA NEWBURY | SEPTEMBER 10, 2025

Comments on the Centers for Medicare & Medicaid Services’ (CMS) 2026 proposed payment rule for ASCs and hospital outpatient departments (HOPD) are due on September 15, 2025. Comments can be submitted online now through the deadline. ASCA will once again submit comments raising industry-wide concerns, but it is important that CMS hears from individual centers as well.

As a special member resource, ASCA staff have created template comment letters that can provide a starting point if you wish to submit comments. You can add your letterhead and customize the letters to your facility’s needs. Templates currently available can help you advocate for:

  • Removal of the secondary rescaling applied to ASCs, a policy that contributes to the growing disparity in reimbursement rates between ASCs and HOPDs
  • Additional codes to be added to the ASC Covered Procedures List (ASC-CPL)
  • Removal of measures from the ASC Quality Reporting Program

ASCA members can access a proposed rule Medicare Rate Calculator (select the 2026 tab under “Rate Calculators by Year”) that shows proposed national and local payment rates for 2026, including rates for the more than 500 codes proposed for addition to the ASC-CPL.

On ASCA’s Medicare Payment Resources webpage, members also can find the text of the rule itself, an analysis that identifies and summarizes major provisions of the rule, and a payment resources document that breaks out ASC-CPL codes into groups such as separately payable, office-based, device-intensive and more. Members must log in to access all resources.

CMS released its proposed rule on July 15 and suggested adding 547 codes to the ASC-CPL in 2026. Many of the codes ASCA requested for inclusion are proposed for addition, including:

Cardiovascular Codes

  • Electrophysiology Studies and Ablations: 93650, 93653, 93654 and 93656
  • Percutaneous Coronary Intervention (PCI): C9602, C9604 and C9607

Spine Codes

  • Posterior Lumbar Interbody Fusion: 22630
  • Combined Posterior Lumbar and Posterior Lumbar Interbody Fusion: 22633

Vascular Code

  • Vascular Embolization or Occlusion: 37244

Of the 574 codes proposed for addition to the ASC-CPL, 271 are musculoskeletal codes that are also proposed for removal from the inpatient-only (IPO) list. CMS has proposed to transition away from an IPO list over a three-year period.

The agency also concurred with ASCA’s request and proposed to continue to align the ASC update factor with the one used to update HOPD payments, extending the interim period an additional calendar year through 2026.

Write Kara Newbury at knewbury@ascassociation.org if you need help customizing your comment letter or have any questions. In addition, ASCA would like to track the number of members who comment, so please email Newbury if you submit comments.