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Reimbursement [Hospital Buyer & Reimbursement](/ecosystems/hospital-buyer)

# ASC Site-of-Service Shift

Migration of procedures from hospitals to ambulatory surgery centers.

Reviewed by [Christian Espinosa, Founder, Blue Goat Cyber](/authors/christian-espinosa) Last reviewed May 5, 2026 

## Definition

Many procedures historically performed inpatient have shifted to ambulatory surgery centers (ASCs) as CMS expanded the ASC-payable procedure list and as physician-owned ASC economics drove adoption - most visibly in orthopedics (total joints) and cardiology. 

What the regulation says

While regulations primarily focus on the safety and effectiveness of medical devices and procedures, the shift to ASCs is influenced by reimbursement policies set by entities such as the Centers for Medicare & Medicaid Services (CMS). These policies, which determine payment rates for procedures performed in different settings, indirectly impact device manufacturers by driving where procedures are performed. Manufacturers must ensure their devices meet all applicable regulatory requirements regardless of the clinical setting, according to regulations like 21 CFR Part 820 for quality systems, even as the site of service changes. 

## What this means in practice

Site-of-service shift compresses device pricing power: ASC payments are typically 60% of HOPD rates. Capital, capital-equipment, and disposables strategies must adapt to ASC budgets. 

## Examples

-   A medical device manufacturer designs a new surgical robot for orthopedic procedures, ensuring its footprint and operational requirements are compatible with the typically smaller operating rooms found in ASCs.
-   A company developing an ocular implant for cataract surgery provides training and technical support tailored to the specific needs and workflows of ASC staff, acknowledging the high volume of these procedures performed in an outpatient setting.
-   A device manufacturer conducts post-market surveillance specifically tracking adverse events and device performance in ASC settings to identify any unique challenges or use errors associated with that environment, fulfilling requirements under 21 CFR Part 803 for medical device reporting.

Common pitfalls

-   • Assuming that regulatory requirements for devices change based on the site of service, rather than remaining consistent across all approved clinical settings. 
-   • Failing to consider the impact of reimbursement policies on product development and market access strategies. 
-   • Overlooking the need for a quality management system that supports devices used in various healthcare settings, including ASCs. 

## Frequently asked questions

How does ASC site-of-service shift affect medical device approvals? 

The site-of-service shift itself does not directly alter the regulatory approval process for medical devices. Device approvals are based on safety and effectiveness data, independent of where the procedure is performed. However, manufacturers may need to provide data relevant to ASCs if the device has specific operational considerations in that setting. 

Are there specific quality system requirements for devices used in ASCs? 

What is the role of human factors engineering in ASC site-of-service shifts? 

## Related terms

Grouped by theme 

### Editor's picks

· Hand-selected related concepts 

[

Reimbursement

Outpatient Prospective Payment System(OPPS) 

Medicare's payment system for hospital outpatient services.





](/terms/opps)[

Reimbursement

Transitional Pass-Through Payment(TPT) 

Supplemental outpatient payment for new device technologies.





](/terms/tpt)

### More in Reimbursement

· Same category 

[

Reimbursement

340B Drug Pricing Program(340B) 

Federal program providing discounted drugs to safety-net providers.





](/terms/340b)[

Reimbursement

Ambulatory Payment Classification(APC) 

The Medicare grouping system that determines hospital outpatient payment amounts under OPPS, analogous to MS-DRGs for inpatient.





](/terms/apc)[

Reimbursement

Budget Impact Model(BIM) 

Financial model that estimates the total cost consequences of adopting a new technology to a payer's budget over a defined horizon.





](/terms/budget-impact-model)[

Reimbursement

Bundled Payment

Single payment that covers all services for an episode of care.





](/terms/bundled-payment)

Cited by

Where this term appears across MedTech Terms.

Ecosystems (1)

-   [Hospital Buyer & Reimbursement](/ecosystems/hospital-buyer)

## Primary references

3 sources 

Link health:  3 verified · last checked 2026-06-20 

CMS· 1 AMA· 1 AdvaMed· 1 

1.  [1 
    
    CMS ASC payment
    
    Verified 
    
    CMS · cms.gov 
    
    
    
    ](https://www.cms.gov/medicare/payment/prospective-payment-systems/ambulatory-surgical-center-asc)
2.  [2 
    
    AMA CPT Resources
    
    Verified 
    
    AMA · ama-assn.org 
    
    
    
    ](https://www.ama-assn.org/practice-management/cpt)
3.  [3 
    
    AdvaMed - Payment & Coverage
    
    Verified 
    
    AdvaMed · advamed.org 
    
    
    
    ](https://www.advamed.org/our-work/)

Inline markers like \[1\]  jump to the matching reference above.

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On this term

Category

Reimbursement

Sources

3

Updated

5/5/2026

[Compare with another term](/compare?a=asc-shift)

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Card Lesson Quiz

Migration of procedures from hospitals to ambulatory surgery centers.

-   · Site-of-service shift compresses device pricing power: ASC payments are typically 60% of HOPD rates. 
-   · Capital, capital-equipment, and disposables strategies must adapt to ASC budgets. 

Remember this

Watch out: Assuming that regulatory requirements for devices change based on the site of service, rather than remaining consistent across all approved clinical settings.

Related terms

-   [Outpatient Prospective Payment System(OPPS) ](/terms/opps)
-   [Transitional Pass-Through Payment(TPT) ](/terms/tpt)

You may also need

Auto-suggested from Reimbursement and shared keywords.

-   [Ambulatory Payment Classification(APC) ](/terms/apc)
-   [ICD-10-CM / ICD-10-PCS ](/terms/icd-10)
-   [HITECH Act(HITECH) ](/terms/hitech-act)
-   [Budget Impact Model(BIM) ](/terms/budget-impact-model)
-   [Inpatient Prospective Payment System(IPPS) ](/terms/ipps)
-   [MS-DRG(MS-DRG) ](/terms/ms-drg)

[All Reimbursement terms](/terms?cat=Reimbursement)

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