The most dangerous regulatory proposals in healthcare are rarely the obvious ones. They arrive as footnotes inside 1,200-page payment rules, framed as technical corrections or beneficiary cost-sharing adjustments. The CMS CY 2027 OPPS proposed rule, released July 2, 2026, contains exactly this kind of proposal - a site-neutral payment expansion targeting noncontrast imaging that would slash reimbursement rates by approximately 60% for services furnished in excepted off-campus provider-based departments.
This is not a modest tweak. It is a structural challenge to how outpatient imaging has been financed for the past decade, affecting hospital outpatient departments, radiology group stipend arrangements, academic department budgets, and the financial viability of imaging programs that anchor community healthcare access in cities and suburbs alike.
The comment deadline is August 31, 2026. After that, the window closes and CMS moves toward a final rule. Every radiology practice leader, hosp…




