OBL-centered perspective on the 2026 ASC Final Payment Rule

Law firm Reed Smith has taken a deep dive into a complex business and regulatory issue: the relationship and competition between office-based labs (OBLs) and traditional ambulatory surgery centers (ASCs), and the changes to that dynamic presented by CMS' 2026 Final Rule for ASCs.

“The landscape for [OBLs] continues to evolve rapidly, creating significant opportunities for interventional radiologists and other procedural specialists,” the firm writes. “While recent updates to the [ASC] Covered Procedures List might seem to favor ASCs, these changes represent a strategic opportunity for OBLs.”

The firm writes that lists of ASC and office-based procedures have “evolved from stringent separation and conservative inclusion to a much more expansive, flexible, and data-driven model. The contemporary process blends clinical evidence, safety criteria, physician judgment, and annual claims review to enable steady growth of office-based procedural options. Expansion to the office-based list is grounded in actual practice patterns and subject to a deliberate payment cap that ensures procedural migration is rooted in clinical need, not financial incentive. These regulatory trends create opportunities for efficient outpatient care delivery – most notably in interventional radiology, minor surgery, and pain management – while requiring active engagement and strategic adaptation by OBL operators and other proceduralists.”

Read the full article, “OBLs vs. ASCs: A Retrospective Payment Policy History with a Promising Future for OBLs Following the CY 2026 ASC Payment Systems Final Rule,” here.