All terms
ReimbursementHospital Buyer & Reimbursement
Site-Neutral Payment
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.
Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed May 9, 2026
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. What the regulation says
Statutory: Section 603 of the BBA 2015 (codified at 42 USC 1395l(t)(21)). CMS implements through annual OPPS rulemaking.
What this means in practice
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.
Primary references
3 sourcesLink health: 2 verified 1 bot-blocked· last checked 2026-05-09
CMS·1Cornell LII·1AMA·1
- 1
CMS — Site-Neutral PaymentsVerifiedCMScms.gov
- 2
42 USC 1395l — Payment for outpatient hospital servicesVerifiedCornell LIIlaw.cornell.edu
- 3
AMA CPT ResourcesBot-blockedAMAama-assn.org
Inline markers like [1] jump to the matching reference above.