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

# Outpatient Prospective Payment System

Medicare's payment system for hospital outpatient services.

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

## Definition

OPPS pays hospital outpatient departments via Ambulatory Payment Classifications (APCs) -  [bundled payment](/terms/bundled-payment) groups for outpatient procedures. ASCs are paid under a parallel ASC payment system tied to OPPS. 

What the regulation says

The Centers for Medicare & Medicaid Services (CMS) administers the Outpatient Prospective Payment System (OPPS), which establishes payment rates for hospital outpatient services and partial hospitalization services in psychiatric hospitals and community mental health centers. The Social Security Act, specifically sections 1833(t) and 1833(a)(2)(E), provides the legal framework for OPPS. CMS updates the OPPS regulations annually, typically through proposed and final rules published in the Federal Register, detailing payment policies and rates. 

## What this means in practice

Annual OPPS rule sets  [APC](/terms/apc) weights, device pass-throughs, and ASC-payable procedure list - a major commercial determinant for outpatient devices. 

## Examples

-   A manufacturer of a novel cardiac diagnostic device for outpatient use ensures the device has sufficient clinical evidence to support a favorable Ambulatory Payment Classification (APC) assignment under OPPS.
-   A company developing an orthopedic implant specifically for ambulatory surgical centers (ASCs) analyzes the annual OPPS rule to confirm its device is included in procedures payable under the parallel ASC payment system.
-   A MedTech firm applies for Transitional Pass-Through status for a new surgical instrument, seeking temporary separate payment under OPPS while CMS gathers data for its permanent integration into an Ambulatory Payment Classification (APC).

Common pitfalls

-   • A common pitfall is misunderstanding the impact of APCs on device reimbursement, assuming direct payment for devices rather than bundled payments for procedures. Another mistake is failing to monitor the annual OPPS rule changes, which can significantly affect market access and pricing strategies for outpatient MedTech. Companies sometimes overlook the distinct but parallel payment system for Ambulatory Surgical Centers (ASCs), leading to incomplete reimbursement strategies. 
-   • It is crucial to differentiate between an outpatient service being covered by Medicare and the specific payment methodology under OPPS, as not all covered services are reimbursed via APCs. 
-   • Some MedTech manufacturers incorrectly assume that device pass-through status is permanent, rather than a temporary payment mechanism subject to specific criteria and time limits. 
-   • Misinterpreting the APC assignment for a new device, or assuming a specific APC will apply without understanding the clinical and cost data CMS uses for classification, can lead to inaccurate financial projections. 

## Frequently asked questions

How do MedTech companies interact with OPPS? 

MedTech companies primarily interact with OPPS by understanding how their devices are incorporated into Ambulatory Payment Classifications (APCs), monitoring device pass-through opportunities, and assessing the impact of annual rule changes on market access and reimbursement for their outpatient products. 

What is a 'device pass-through' in OPPS? 

How does OPPS affect product development? 

## Related terms

Grouped by theme 

### Editor's picks

· Hand-selected related concepts 

[

Reimbursement

ASC Site-of-Service Shift

Migration of procedures from hospitals to ambulatory surgery centers.





](/terms/asc-shift)[

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 OPPS
    
    Verified 
    
    CMS · cms.gov 
    
    
    
    ](https://www.cms.gov/medicare/payment/prospective-payment-systems/hospital-outpatient)
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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MedTech Terms is a community resource sponsored by [Blue Goat Cyber](https://bluegoatcyber.com). Definitions are independent of any vendor.

On this term

Category

Reimbursement

Acronym

OPPS

Sources

3

Updated

5/5/2026

[Compare with another term](/compare?a=opps)

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Card Lesson Quiz

Medicare's payment system for hospital outpatient services.

-   · Annual OPPS rule sets APC weights, device pass-throughs, and ASC-payable procedure list - a major commercial determinant for outpatient devices. 
-   · ASCs are paid under a parallel ASC payment system tied to OPPS. 

Remember this

Watch out: A common pitfall is misunderstanding the impact of APCs on device reimbursement, assuming direct payment for devices rather than bundled payments for procedures. Another mistake is failing to monitor the annual OPPS rule changes, which can significantly affect market access and pricing strategies for outpatient MedTech. Companies sometimes overlook the distinct but parallel payment system for Ambulatory Surgical Centers (ASCs), leading to incomplete reimbursement strategies.

Related terms

-   [Transitional Pass-Through Payment(TPT) ](/terms/tpt)
-   [ASC Site-of-Service Shift ](/terms/asc-shift)

You may also need

Auto-suggested from Reimbursement and shared keywords.

-   [Ambulatory Payment Classification(APC) ](/terms/apc)
-   [Site-Neutral Payment ](/terms/site-neutral-payment)
-   [MS-DRG(MS-DRG) ](/terms/ms-drg)
-   [Inpatient Prospective Payment System(IPPS) ](/terms/ipps)
-   [Bundled Payment ](/terms/bundled-payment)
-   [Medicare Physician Fee Schedule(MPFS) ](/terms/physician-fee-schedule)

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

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