The Medicare Inpatient Only (IPO) List, introduced in 2000 as a component of the implementation of the Outpatient Prospective Payment System (OPPS), has remained a dynamic and evolving element of the OPPS framework. Originally designed to restrict outpatient payment for services deemed potentially unsafe or inappropriate for the outpatient setting—particularly those requiring extended monitoring before discharge—the IPO list has undergone annual updates to reflect changes in medical practice, patient care, and regulatory standards. These updates have taken into account scenarios such as patient expiration, evolving admission requirements, and advancements in modern medicine.
Each year, during the OPPS review process, CMS evaluates the IPO list using specific criteria:
- Most outpatient departments are equipped to provide the service or procedure to the Medicare population.
- The simplest version of the service or procedure described by the code can be performed in most outpatient departments.
- The service or procedure is related to codes that CMS has already removed from the IPO list.
- The service or procedure is being performed in numerous hospitals on an outpatient basis.
- The service or procedure can be safely and appropriately performed in an ambulatory surgical center and is either specified as a covered ambulatory surgical procedure or proposed to be.
While the CY2025 update included only a handful of changes to the IPO list, the CY2026 proposed rule presents a significant shift: CMS is proposing to phase out the IPO list entirely over a three-year period starting in 2026.
Sound familiar? A similar proposal was introduced in 2021 but was halted in 2022. Notably, the criteria used to evaluate IPO list removals were codified in §419.23 of the Code of Federal Regulations.
Currently, the IPO list includes 1,731 services. For CY2026, CMS proposes to begin the phase-out by removing approximately 285 musculoskeletal services. It will be critical for stakeholders to engage during the comment period, monitor the final rule, and stay informed about ongoing updates to the IPO list.
Keeping track of these frequent and complex changes in healthcare regulations can be overwhelming. That’s where solutions like the MediRegs Master Suite come in. This platform streamlines the tracking of federal and state healthcare news, coding and reimbursement updates, and allows users to follow key industry topics through customizable News Alerts. Tools like the Code Explorer and the scenario-based OPPS Calculator help flag issues such as IPO-listed codes. Additionally, the OPPS eBook simplifies the review of both proposed and final OPPS rules, while the APC Payment Book clarifies OPPS logic, including IPO list updates.
Once the Final Rule is released, providers must act quickly to implement changes impacted by the IPO list and other OPPS modifications. These updates may require revisions to systems such as the Charge Description Master (CDM) and necessitate education for revenue cycle and clinical teams. For IPO list changes specifically, it’s essential to educate Providers, Utilization Review, and Patient Access staff. MediRegs products support this process by providing timely access to the latest OPPS-related information and tools to stay compliant and informed.
