Site-Neutral Imaging Payment Threat 2027

CMS just proposed the most disruptive radiology payment shift in years. 🚨

Site-neutral imaging payments are coming for hospital outpatient departments. If you run, bill for, or contract with an outpatient imaging program, you need to understand what changed.

Here is the framework.

THE CY 2027 SITE-NEUTRAL IMAGING FRAMEWORK
(Based on the CMS CY 2027 OPPS Proposed Rule, summarized by the ACR)

1. WHAT IS CHANGING
CMS proposed expanding site-neutral payment to noncontrast imaging services furnished in excepted off-campus provider-based departments (PBDs). These are the grandfathered hospital outpatient departments protected under Section 603 of the Bipartisan Budget Act of 2015. They have been billing at higher OPPS rates for years. That protection is now being challenged.

2. WHICH IMAGING SERVICES ARE IN SCOPE
– CT imaging without contrast
– MRI and MRA imaging without contrast
– Radiography
– Ultrasound

Contrast-enhanced studies and more complex imaging categories are NOT included in this initial proposal. But according to the ACR, CMS is expected to expand site-neutral payment across radiology and other services over time.

3. WHAT SITE-NEUTRAL MEANS IN PRACTICE
Instead of OPPS facility rates, these services would be reimbursed at rates aligned more closely with Medicare Physician Fee Schedule payments. The same service, lower payment, simply because the facility is no longer treated as a traditional hospital outpatient setting.

4. WHO GETS HIT AND HOW
– Radiologist-owned imaging centers: Already absorbing year-over-year Medicare PFS cuts, skyrocketing labor costs, and workforce challenges. This adds another hit.
– Academic radiologists and private practice radiologists with professional-component-only models: Stipends and department support could be jeopardized if the hospital’s technical revenue from outpatient imaging drops.
– Hospital health systems: Argue that outpatient departments carry extra costs, including emergency services, complex patient care, and additional regulatory requirements, that freestanding centers do not.

5. THE POLICY RATIONALE CMS IS USING
The underlying question is straightforward, according to the ACR. If the same clinical service is provided with similar resources, should Medicare pay substantially different amounts based solely on whether the facility is hospital-owned?

CMS argues site-neutral payment reduces Medicare spending, decreases beneficiary cost-sharing, and reduces consolidation incentives.

Save this framework for your next budget or contract conversation.

Comments on the proposed rule are due August 31, 2026. The ACR is preparing a formal comment letter.

This is not just a reimbursement tweak. It is a structural challenge to how outpatient imaging has been financed for a decade.

Every imaging center operator, radiology chair, and health system CFO needs to model the impact of this before the final rule drops later this year.

The facilities that wait and see will be the ones scrambling in January.

👉 Follow Jonathan Govette, CEO of Oatmeal Health, for daily healthcare insights on LinkedIn. Deeper dives in The Oatmeal Bite on Substack: https://news.oatmealhealth.com