CMS-1850-P: The Four Numbers That Matter

01 — The Real Update

+1.9%

CMS proposes a 2.4% gross OPD fee schedule increase factor — but the rule's own Regulatory Impact Analysis states total OPPS payments rise 1.9% after budget-neutral adjustments, outlier changes, the frontier State wage adjustment, and the new imaging policy. Budget on 1.9%, not 2.4%.

02 — Rule-Attributable Impact

+$1.82B

Federal OPPS expenditures rise ~$1.82B CY2026→CY2027 (Table 91 accounting statement). Distinct from the broader ~$9.5B total OPPS expenditure growth, which reflects enrollment, utilization, and case-mix — not this rule's policies.

03 — The 340B Hit

−$2.3B

The 340B non-drug conversion-factor offset triples from 0.5% to 3.0 percentage points, cutting OPPS payments by ~$2.3B in CY 2027. CMS projects its $7.8B recoupment target now completes by CY 2029 — versus CY 2041 under the prior rate. 340B hospitals should model this now.

04 — Imaging, Correctly Framed

−$260M

Off-campus PBD imaging without contrast moves to PFS-equivalent rates: $260M reduced CY2027 payments ($190M Medicare savings + $70M beneficiary coinsurance reduction).

The widely cited “$7.2B imaging cut” is a real but separate figure — CMS's estimate that Medicare Advantage baseline spillover lowers net Part B spending by $7.2B cumulatively over 2027–2036. It is not a general imaging reduction. We verified the difference so you don't have to.