In Medicare’s 2022 proposed payment rule for hospital outpatient departments (HOPD) and ASCs, when trying to justify the removal of hundreds of codes from the ASC Covered Procedures List (ASC-CPL) that are reimbursed in the HOPD setting, the Centers for Medicare & Medicaid Services (CMS) argued that “while there are similarities between the ASC and HOPD settings, there are also significant differences between the two care settings.”