Friday, October 30, 2026

When Will CMS PRS and OPPS Final Rules Appear? Today? Next Week? CLAUDE knows.

 Annual "final rules" for Physician Fee Schedule and Outpatient Prospective Payment System (PFS and HOPPS or OPPS) come out around November 1, always after "market close."  November 1, so they are 60 days ahead of the implementation date of January 1, 2027.

I asked Claude for a look-back and here's what I got.  BTW the query took about a minute.  The rules are named for the upcoming calendar year. Today on October 30, 2026, we're awaiting the rule for CY27.

Short answer: November 1 and November 2 each appear about half the time.  Usually, both rules on same day.    

And: Claude, 1 minute, Chat GPT 4 minues.  All answers matched.


#### CLAUDE


Here’s the ten-year record (CY2017 through CY2026 rules, released 2016–2025), based on CMS fact-sheet dates, Federal Register public-inspection notices, and same-day trade press. Dates are the “inspection copy” posting, not the later paginated FR publication.

A few points of documentation. For CY2017, on Wednesday, November 2, 2016, CMS issued the PFS final rule, while the OPPS came a day earlier: on November 1, 2016 CMS published the CY 2017 Final Rule which included payment rates and policy changes to the OPPS and ASC Payment System. Your own blog from that week is in the search results confirming the Nov 2 PFS date. The CY2018 pattern was identical: on November 1, CMS released the CY 2018 OPPS/ASC final rule; on November 2, it released the CY 2018 PFS final rule. CMS’s own PFS page states the final rule went on display at the Office of the Federal Register’s Public Inspection Desk on November 2, 2017, and will be available until the regulation is published on November 15, 2017. Fact Sheets Nov 02, 2016 +3

CY2019 reversed the order. On November 1, 2018, CMS finalized the 2019 MPFS rule, and on November 2, 2018, CMS released a final rule implementing changes to the OPPS and ASC Payment System for CY 2019. For CY2020, both landed together: on Friday, November 1, CMS released the CY 2020 final rules for the PFS, OPPS and Quality Payment Program, which you noted at the time as “on time” despite the late-July proposed rules. CMS Finalizes 2019 Physician & Outpatient Fee Schedules +2

CY2021 is the outlier on the late side. The final 2021 MPFS was released on December 1, 2020, with HFMA recording that on December 2, 2020, CMS placed on public display a final rule relating to the Medicare physician fee schedule for CY 2021 (the rule was posted to CMS.gov the evening of Dec 1 and hit the Federal Register inspection desk the next morning, so both dates are defensible depending on your definition). CMS noted it was waiving the 60-day delay in effective date (in accord with the Congressional Review Act). The OPPS followed: CMS released the CY 2021 final rule with comment for OPPS and ASC on December 2, 2020. In Case You Missed It: 2021 CMS Final Rules Released +3

The next four years were clockwork, with both rules on the same day each time. CY2022: on November 2, 2021, CMS issued its CY 2022 MPFS Final Rule. Simultaneously, CMS released its CY 2022 OPPS Final Rule with comment period. CY2023: CMS Nov. 1 posted its CY 2023 OPPS and ASC final rule, and the PFS was released the same Nov 1, 2022 (some law-firm alerts say Nov 2, reflecting FR filing the next morning, but the CMS fact sheet and most same-day coverage say Nov 1). CY2024: on November 2, 2023, CMS released the final rules for the CY 2024 OPPS and ASC payment system, 340B drug reimbursement, and CY 2024 PFS. CY2025: on November 1, 2024, CMS placed on public display the PFS final rule for CY 2025, and the CY 2025 OPPS/ASC final rule (CMS-1809-FC) on November 1, 2024. Articles and Blogs +4

CY2026 broke the pattern in both directions. The PFS came out early, on Halloween: on October 31, 2025, CMS released the PFS final rule for CY 2026. The OPPS, however, did not appear until November 21, 2025, which McDermott+ characterized this way: Medicare rules are usually required to be released 60 days prior to their effective date (which in this case would have been November 1, 2025), and although the rule came out “late,” the effective date will still be January 1, 2026. The October 1–November 12 federal shutdown is the obvious explanation, and it’s worth noting that CMS evidently had the PFS far enough along to push it out the door during the shutdown while the OPPS sat until the week after reopening. key updates on the 2026 medicare physician fee schedule +2

So, tallying the twenty releases: Nov 1 appears nine times, Nov 2 eight times, with Oct 31 once, and three genuine outliers (Dec 1/2 in 2020 and Nov 21 in 2025). Your “Oct 31 / Nov 1 / Nov 2” heuristic covers 17 of 20. The day-of-week pattern is also informative: CMS has never released on a weekend, and when Nov 1 falls on a Saturday (as it did in 2025) they go to Friday Oct 31 rather than Monday Nov 3. That is a useful data point for this year, since Nov 1, 2026 falls on a Sunday, which argues for Friday Oct 30 (today) or Monday Nov 2.

Sources:

Note: Above includes some McDermott dead links (see here), see below for all the CMS fact sheets.  Which both confirm date of inspection copy release, and, of course, probably lots of interesting reading.

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CY2017 (released 2016)

CY2018 (released 2017)

CY2019 (released 2018)

CY2020 (released 2019)

CY2021 (released 2020)

CY2022 (released 2021)

CY2023 (released 2022)

CY2024 (released 2023)

CY2025 (released 2024)

CY2026 (released 2025)

####

Two caveats. For the three oldest OPPS rules (CY2017–CY2019), the fact sheets lived on CMS’s pre-2019 “MediaReleaseDatabase” URL scheme, which was retired when the newsroom was rebuilt; those links now redirect unreliably, so I substituted the CMS regulation pages (CMS-1656-FC, -1678-FC, -1695-FC), which are stable and carry the display and publication dates. And the CMS newsroom fact-sheet slugs ending in -0 or -2 are CMS’s own de-duplication of near-identical proposed-rule and final-rule titles, not typos; dropping the suffix lands you on the proposed-rule fact sheet.

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CHAT GPT / Slower, 4 minutes

Both tables match (per inspection by both Chat and Claude and me.)


Your expectation is largely right: 17 of the 20 releases fell on October 31, November 1, or November 2. The exceptions were both rules in 2020 and OPPS in 2025.

I treated “last ten years” as release years 2016–2025, covering rules effective in CY 2017–2026. These are the initial public-release dates, based on CMS’s dated final-rule announcements—not the later dates of publication in the paginated Federal Register. Each linked date below opens the corresponding CMS source.

A few findings stand out:

  • November 2 is not merely a weekend adjustment. In 2021, November 1 was Monday, yet both rules appeared Tuesday. In 2023, November 1 was Wednesday, yet both appeared Thursday.
  • PFS and OPPS need not arrive together. They appeared on the same date in only five of the ten years.
  • 2020 was an exceptional delay. The PFS rule explicitly explained that resources devoted to the COVID-19 response justified waiving the usual 60-day delay and substituting 30 days. See the rule’s discussion of the waiver.
  • The November 21, 2025 OPPS date is also real. Its final rule expressly waived the 60-day delay to retain a January 1, 2026 effective date. See the final rule.

For an additional check on the distinction you emphasized, the Federal Register’s filing footers corroborate the CMS dates for all six releases in 2016–2018. For example, the 2017 PFS release was filed November 2 at 4:15 p.m., although the paginated rule was published November 15.