The Gist Healthcare Podcast

Site-Neutral Payment Is Coming. How Should Health Systems Prepare?

Mar 2, 2026
Joyjit Choudhury, Managing Director at Kaufman Hall who advises health systems on strategy and policy shifts, discusses site-neutral payment becoming operational reality. He explains Medicare’s 2026 drug administration change. He outlines a three-stage prep: assess impact, craft strategy, and execute. He reviews data-driven modeling and options like defend, extend, manage, and pursue for health system strategy.
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INSIGHT

Site Neutrality Has Become Operational Reality

  • Site-neutral payment is shifting from policy debate to operational reality for health systems.
  • Medicare's 2026 OPPS rule added drug administration to site-neutral rules, signaling more services will likely follow and forcing planning now.
ADVICE

Use A Three Stage Planning Playbook

  • Do structure your preparation in three stages: impact assessment, strategy formulation, and strategy execution.
  • Combine public market data, your service-by-site contribution margins, and payer contract details to model a range of financial impacts.
ADVICE

Model Scenarios Not Single Predictions

  • Do build scenario models because definitive answers about scope and timing are unavailable.
  • Merge service-level site data, contribution margins by site, and payer contract terms to estimate a range of possible impacts.
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