CMS has proposed reforms that would push Medicare toward site-neutral payments — eliminating the premium hospitals charge for outpatient services performed in hospital-owned clinics versus independent physician offices — and would cut reimbursement rates under the 340B drug discount program, which reached $100 billion in sales in 2025.
CMS's Site-Neutral and 340B Cuts Would Squeeze Hospital Systems and Hand Wins to Outpatient Rivals
A proposed CMS rule targeting hospital payment premiums and 340B drug discounts puts large health systems on defense.

Site-neutral payments would erase the billing premium that hospital-owned outpatient clinics have used to undercut independent rivals for years.
Who cashes in: Independent ambulatory surgery centers and physician-owned outpatient groups are the structural winners; they've long competed at a price disadvantage against hospital outpatient departments. Publicly traded ASC operators like Surgery Partners (SGRY) and United Surgical Partners (private, majority-owned by Tenet Healthcare THC) benefit as the payment gap narrows. On the 340B side, large pharmacy benefit managers and specialty pharmacies that sit outside the 340B program — including CVS Health CVS and Cigna/Evernorth (CI) — face less margin compression from 340B-subsidized competition.
Who's exposed: Large nonprofit and for-profit hospital systems are the direct losers. HCA Healthcare HCA, Tenet Healthcare THC, and Universal Health Services UHS all derive significant revenue from the outpatient premium that site-neutral rules would eliminate. Community health systems that rely heavily on 340B drug revenue — particularly safety-net hospitals — face a double hit. The American Hospital Association has already signaled legal challenges, so implementation is not guaranteed.
What to watch next: The comment period and any subsequent litigation will determine timing. Watch for HCA and Tenet management commentary on the magnitude of revenue at risk. If the rule survives legal challenge and is finalized, outpatient-focused operators like Surgery Partners could see a meaningful re-rating.
Source: original report ↗
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