Reimbursement
Site-Neutral Payment
In one line
Medicare payment policy that pays the same amount for a service regardless of whether it is delivered in a hospital outpatient department, ASC, or physician office.
Definition
Site-neutral payment is the policy principle — partially implemented by Medicare since the Bipartisan Budget Act of 2015 (Section 603) — that the same outpatient service should be reimbursed at the same rate regardless of setting. Section 603 made off-campus hospital outpatient departments established after November 2, 2015 paid at the lower Medicare Physician Fee Schedule equivalent rate, not the higher OPPS rate. Multiple subsequent legislative proposals would extend site-neutral payment more broadly.
Why it matters
Site-neutral expansion is one of the largest swing factors for hospital outpatient economics and for the ASC migration trend; MedTech teams must model both scenarios in their reimbursement analysis.
Common pitfalls
- •Building a launch case on HOPD rates without modeling site-neutral expansion risk.
Sources
- CMS — Site-Neutral Payments · CMS
- 42 USC 1395l — Payment for outpatient hospital services · Cornell LII
- AMA CPT Resources · AMA