Key Takeaways for Echocardiographers

On November 21, 2025, CMS released the CY 2026 Outpatient Prospective Payment System/Ambulatory Surgical Center (OPPS/ASC) Final Rule, updating Medicare payment policies for hospital outpatient departments and ASCs. These policies affect roughly 4,000 hospitals and 6,000 ASCs and include several provisions relevant to cardiovascular imaging, quality reporting, and emerging software-based technologies.

Payment Updates

CMS finalized a 2.6% OPPS payment increase and a 2.6% ASC update for facilities meeting quality reporting requirements. These adjustments reflect a 3.3% market basket update offset by a 0.7% productivity reduction.  Overall, imaging APCs remained relatively stable, with a modest increase for echocardiography APCs 5524 and 5523.

Quality Programs

CMS finalized updates to the:

  • Hospital OQR Program
  • ASCQR Program
  • Rural Emergency Hospital Quality Reporting Program

Notably, CMS is revising the Overall Hospital Quality Star Rating to give greater weight to Safety of Care, which may affect how imaging services are incorporated into quality measurement frameworks.

Site-of-Service Policy Changes

CMS expanded its policy to curb unnecessary volume shifts to excepted off-campus PBDs. Beginning in CY 2026, drug administration services in these PBDs will be paid at Physician Fee Schedule – equivalent rates, reducing OPPS spending by an estimated $290 million. Although this change does not directly affect echocardiography, it reflects CMS’s continued push toward site-neutral payment policy; an area ASE will continue monitoring.

Software as a Service (SaaS)

CMS again highlighted the challenges of paying for clinical software tools, including AI-driven and image-analysis platforms increasingly used in echocardiography. The agency received extensive comments on future payment methods for SaaS under both the OPPS and PFS and indicated it will consider this feedback in future rulemaking. This remains an important policy space for ASE given the growing role of AI-enabled echocardiography interpretation and reporting tools.

ASC Covered Procedures List (ASC-CPL)

CMS finalized broad updates to the ASC-CPL criteria for CY 2026, revising the general standards and eliminating the inpatient-only exclusion criteria for many procedures, which are now recast as nonbinding physician safety considerations to guide case selection. As a result of these changes, 289 new procedures have been added to the ASC-CPL, and 271 additional procedures previously limited to the inpatient setting are now eligible to be performed in ASCs when clinically appropriate.

These changes underscore CMS’s continued commitment to expanding outpatient flexibility and revisiting site-of-service assumptions as technology and clinical practice advance.

Of particular relevance to ASE members, several interventional cardiology and electrophysiology services, as well as key echocardiography codes 93312 and 93318, are now included in the APC covered services listing. This opens the door to broader use of echocardiography in outpatient and ASC settings. ASE will continue to closely monitor these developments to ensure echocardiography services are accurately recognized, appropriately approved, and fairly reimbursed across all relevant outpatient and ASC sites of service.

 

Newly Allowed CPT®/HCPCS Codes in ASCs

93312 Transesophageal echocardiography; probe placement, image acquisition, interpretation
93318 Transesophageal echocardiography for monitoring during percutaneous procedures
C8925 Transesophageal echocardiography with contrast (or without contrast followed by with contrast), real-time 2D imaging
C8926 Transesophageal echocardiography with contrast for congenital cardiac anomalies
C8927 Transesophageal echocardiography with contrast for monitoring purposes (continuous assessment)

 

Additional Resources

 

Publish date

November 26, 2025

Topic

  • Advocacy
  • CMS Rules
  • Physician Payment