The CY2027 Infusion Reset

Your drug line is the exposure. Not your fee schedule.

For an infusion business, CY2027 is not a rate-update year — it is a gross-margin event. The Physician Fee Schedule moves your administration revenue by single-digit percentages. The OPPS 340B proposal moves 37% of the payment on every 340B-acquired drug dollar. On a buy-and-bill service line, that is the whole margin and then some.

Drug acquisition economics come from OPPS; administration and telehealth come from the PFS. They have to be modeled together, because a policy that helps one side can be more than offset on the other — and in the same rule that cuts HOPD drug payment, HOPD administration payment goes up.

Everything hitting infusion in CY2027

Two rules, two comment deadlines, one effective date. The table below is the complete list of provisions that reach an infusion service line — including one that is already final and in effect.

ASP + 6% to ASP − 33.4% is a 37.2% revenue cut

The headline is often quoted as "a 33.4% cut." It is not. Payment moves from 106% of ASP to 66.6% of ASP — a 37.17% reduction in Medicare payment per drug dollar. Applied to a buy-and-bill line with high acquisition cost and thin spread, the arithmetic is unforgiving.

CMS picked the most aggressive number in its own range

The rate comes from the Medicare OPPS Drug Acquisition Cost Survey (ODACS), run January 1 – April 7, 2026 under Executive Order 14273. The survey cured the defect the Supreme Court identified in AHA v. Becerra — but the way CMS used the results creates distinct exposure points for comment and, if finalized, for litigation.

The offset is real — and it is not yours

Budget neutrality means CMS must give back what it takes from 340B drugs. It does so by raising the non-drug OPPS conversion factor +8.44% — for every OPPS hospital, including non-340B competitors that absorb none of the cut. Then it takes 3% back from legacy hospitals through the accelerated remedy offset. Net, the non-drug side moves roughly +7.7%, against a −37.2% cut on drugs.

Before any offsetting non-drug conversion-factor gain, and before beneficiary coinsurance effects. CMS estimates $4.55B in Medicare drug payment and $1.15B in beneficiary drug payments removed in year one.

The drugs infusion centers actually bill, per administration

The percentage is identical for every J code — −37.17% — because the change is a multiplier on ASP. What differs, and what matters to a CFO, is the dollar loss per administration and how many administrations you run. High-cost, low-frequency biologics carry the largest single-claim exposure.

Office infusion administration is cut where it hurts most

Removing the Indirect Practice Cost Index concentrates the damage in first-hour codes, which carry the practice-expense load. Subsequent-hour and injection codes move only with the conversion factor. Medical oncology's IPCI falls from 1.94 to 1.46 — the largest correction of any specialty in the rule.

National unadjusted amounts, no GPCI. Non-QP conversion factor $33.4009 → $32.8409; QP $33.5675 → $33.1693. Every figure independently recalculated by Fulcrum Health Partners from Addendum B RVUs × the applicable conversion factor. The rest of the administration stack — hydration (96360/96361), sequential and concurrent infusion (96366–96368), IV push (96374/96375, 96409/96411), SC/IM and hormonal chemo admin (96401/96402), pump refill and maintenance (96521–96523), and home infusion professional and nursing visits (G0068, G0088/G0089) — carries a −1.68% floor.

Administration is the smaller number. It is also the number most infusion centers already run at or below cost — which is precisely the comment argument.

Office administration falls while HOPD administration rises

The two rules push in opposite directions on the same service. On the professional side, IPCI removal cuts office administration. On the facility side, 340B budget neutrality inflates the non-drug conversion factor, lifting HOPD drug-administration APCs. For the same infusion, the CY2027 payment gap between an on-campus HOPD and a physician-office infusion center widens materially.

Hospitals hold roughly 40% of Part B drug spend. Some of it is now unprofitable.

For two decades the direction of travel has been one-way: infusion volume moving from physician offices into hospital outpatient departments, driven substantially by 340B spread. CY2027 attacks the economics of exactly that migration. The relevant question for a CFO is no longer whether the shift reverses, but which specific therapies stop covering their own drug cost in an HOPD.

MedPAC Payment Basics and Data Book series. The trend has continued past 2019; Fulcrum Health Partners could not source a verified post-2019 split for this briefing and recommends refreshing against the current MedPAC Data Book, Section 10, before external use. On the provider side, CMS states the payment policies affect approximately 3,500 OPPS hospitals — most of them pre-2018 Medicare enrollees who also absorb the 3% remedy offset — and 6,400 ASCs, which get the +2.4% update and are not 340B-eligible.

The one unambiguously good news item for infusion

Infusion is a telehealth-heavy service line in ways that are easy to overlook: pre-infusion assessment and clearance, toxicity and tolerance check-ins between cycles, home-infusion nurse oversight, port and line troubleshooting, and financial-toxicity counselling. CY2027 preserves the flexibilities that make those workflows billable — but on a defined clock, not permanently.

These reflect the Consolidated Appropriations Act, 2026 — statutory extensions reflected in the rule, not CMS discretion, which means the next cliff is a legislative risk rather than a rulemaking risk. New telehealth codes proposed: GAPC1 · GAPC2 (advanced primary care management in a telehealth context), GSMAS (shared medical appointment services), GSLPP (speech-language pathology), and GADV1 (advanced / additional telehealth service). Also in the rule: RPM and RTM would require an initiating visit, RTM would require established-patient status, and delivery must be by employed clinical staff rather than contractors — with device valuations reduced. Infusion programs using contracted remote-monitoring vendors should re-paper those arrangements.

1. Pre-infusion clearance and consent

   Remote assessment of labs, performance status, and premedication tolerance before the patient travels — the highest-value use of the home-as-originating-site flexibility, and the one that most reduces chair no-shows and wasted mixed doses.

2. Inter-cycle toxicity monitoring

   Audio-only continuity through January 2028 matters disproportionately here, because the patients most likely to have a reaction are often the least likely to have reliable video.

3. Home-infusion nurse and pharmacist oversight

   As therapy shifts out of the HOPD under the 340B economics, telehealth is the supervision mechanism that makes the shift clinically defensible.

4. Financial navigation and prior-authorization counselling

   Increasingly material as beneficiary coinsurance falls with the drug rate — CMS estimates $1.15B less in beneficiary drug payments, which changes the patient conversation.

5. Shared medical appointments

   The proposed GSMAS coding, plus new coding for shared appointments in the rule, opens a modest but real avenue for group education in oncology and chronic-biologic populations.

The Medicare cut becomes a commercial cut automatically

Most infusion operators discover this too late. A large share of MA and commercial agreements are written as a percentage of the Medicare rate or of ASP — so when CMS republishes the schedule on January 1, those contracts reprice themselves with no renegotiation trigger, no notice, and no amendment. The 37% cut can arrive across your entire book.

1. 340B carve-out

   Drug reimbursement is set by reference to the non-340B Medicare rate (ASP + 6%), regardless of how the drug was acquired. Fallback if refused: a blended rate that assumes a stated 340B mix, fixed for the term.

2. Rate floor

   Drug payment shall not fall below the greater of a stated percentage of ASP or the CY2026 fee schedule amount. Fallback: a floor limited to a defined high-cost drug list.

3. Fixed-year indexing

   Replace "current-year Medicare" with "CY2026 Medicare," repriced only by mutual amendment. Fallback: an annual cap on downward movement, e.g. −2%.

4. Regulatory-change reopener

   Either party may reopen drug reimbursement on a material change in the Medicare methodology, with a defined negotiation window. Fallback: a reopener limited to changes exceeding a stated threshold.

5. Administration-fee protection

   Fix administration codes to CY2026 PFS amounts or a stated dollar schedule, decoupled from RVU changes. Fallback: hold administration at current-year rates for the term.

6. Site-of-care neutrality

   If the payer requires or incentivizes a site shift, the rate follows the therapy rather than the setting. Fallback: a written site-of-care policy with a defined exception process.

Four workstreams, two hard deadlines

OPPS comments on CMS-1850-P are due August 31; PFS comments on CMS-1848-P are due September 14. Final rules are typically released in November 2026, and rates and modifiers take effect January 1, 2027. The comment window is the only point in the cycle where the rate itself is still movable; everything after it is mitigation.

Method and limitations

All arithmetic in this briefing was computed programmatically and independently checked, not transcribed from secondary summaries. Every rate in the administration tables was recalculated from Addendum B RVUs multiplied by the applicable conversion factor. The 340B factor is exact: 0.666 ÷ 1.06 − 1 = −37.17%. The ASP − 28% alternative is 0.72 ÷ 1.06 − 1 = −32.08%. The net non-drug OPPS conversion-factor effect is computed multiplicatively: 1.024 × 1.0844 × 0.97 − 1 = +7.71%. PFS amounts are national unadjusted; no geographic practice cost index has been applied.

Four limitations to read before external use. J-code dollar amounts are illustrative planning magnitudes, not published rates — ASP limits change quarterly and vary by product mix, so the dollar columns must be rebuilt from your own ASP payment limit file. HOPD administration rates are unconfirmed, coming from third-party analysis Fulcrum has not been able to tie to a CMS source document; validate against CMS-1850-P Addendum B. Part B drug spending by setting is 2019 data and should be refreshed from the latest MedPAC Data Book. 340B hospital counts could not be verified — only the PPS-exempt cancer hospital count (11) and the CMS provider counts (~3,500 OPPS hospitals, ~6,400 ASCs) are sourced. These are proposed rules: provisions may change materially in the final rules, expected around November 2026, and the 340B rate faces a meaningful probability of legal challenge.