National Daily Hospital Executive Briefing — August 30, 2025

6 Key Takeaways for Executives

IPPS FY 2026 Final Rule
Base rates and policy changes are finalized. Review your hospital’s CMS impact files today to assess changes in DRG weights, wage index, and quality program adjustments.
- Final rule details:
  https://www.federalregister.gov/documents/2025/08/04/2025-14681/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-ipps-and
- CMS summary:
  https://www.cms.gov/medicare/payment/prospective-payment-systems/acute-inpatient-pps/fy-2026-ipps-final-rule-home-page
Physician Fee Schedule (PFS) CY 2026 – Proposed Rule
A proposed ~3.3–3.8% increase in the conversion factor is being considered, with variances depending on Q-APM status. Time-based evaluation and management (E/M) codes are likely to see proposed adjustments. Prepare comments now, focused on your primary care and behavioral health billing mix.
OPPS/ASC CY 2026 – Proposed Rule
Public comment period is open. Review proposed service-line changes—especially any packaging changes and imaging or radiopharmaceutical policy shifts (e.g., Tc-99m).
- CMS rule info:
  https://www.cms.gov/medicare/payment/prospective-payment-systems/hospital-outpatient
California SB 525 – Healthcare Minimum Wage
Wage floors under SB 525 are being phased in. Confirm which category your facility falls into, then refresh payroll models accordingly, including benefits and compression effects.
- AP News overview:
  https://apnews.com/article/6f9b449763d0e7c5e093c2de672ce616
- California Department of Industrial Relations breakdown:
  https://www.dir.ca.gov/iwc/MW-2025-SUPPLEMENT-health-care.pdf
Hospital Price Transparency – Intensified Enforcement
CMS is publicly tracking enforcement actions and outcomes. Ensure your machine-readable files are fully accurate—no placeholder prices. Implement routine audits.
- CMS enforcement data:
  https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/hospital-price-transparency-enforcement-activities-and-outcomes
- Guidance for systems:
  https://www.trekhealth.io/resources/navigating-the-2025-cms-price-transparency-updates-what-health-systems-need-to-know
Emergency Department Boarding Trends
Boarding is increasing, especially for pediatric mental-health visits and older adults. Current data: >10% of children’s mental-health ED visits involve boarding; elderly boarding times are rising.
- Children’s study:
  https://www.beckershospitalreview.com/care-coordination/1-in-10-childrens-ed-visits-for-mental-health-lead-to-boarding-study
- Older adults report:
  https://www.ajmc.com/view/prolonged-ed-stays-boarding-times-among-older-adults-underscore-systemic-hospital-strain
- General overview:
  https://apnews.com/article/f906664b9c47ea603c9a49b99efbe36e

Policy & Payment Action Items (This Week)

IPPS FY 2026 Final Rule
Retrieve your facility’s CMS impact reports. Analyze changes to case-mix, wage index, and quality adjustments. Host a CFO/CNO session to evaluate any shifts in service-line profitability.
PFS CY 2026 Proposed Rule
Prepare comment submissions, emphasizing time-based E/M codes, behavioral health access, and telehealth. Model impacts based on your billing distribution.
OPPS/ASC CY 2026 Proposed Rule
Engage department leaders—mandate focused reviews of proposed changes in imaging, cath labs, outpatient surgery. Flag any service-line changes exceeding ±2% financial impact.

Workforce & Labor

Implement SB 525 Compliance (CA-only)
Finance teams must ramp the payroll model to include new wage floors by facility type, modeling wage, compression, and benefit shifts. Refresh contracts and payer assumption forecasts.

Compliance & Risk

Price Transparency
Conduct immediate machine-readable file audits—verify there are no placeholder values. Schedule quarterly cross-functional audits involving RevCycle, IT, and Legal to ensure accuracy.
No Surprises Act & IDR Risk
Current trends show dispute resolution (IDR) usage increasing total costs. Review OON mechanisms, bolster documentation, and monitor pending updates to CMS rules and portals.
Non-Compete Enforcement
The FTC’s attempt to outlaw non-competes remains blocked by court action. Continue relying on state-law-compliant covenants, confidentiality, and IP clauses for your workforce.

ED & Patient Flow Interventions

Rising Boarding Rates
Response steps for the next 30–60 days:
- Launch daily bed-capacity huddles with med/surg, behavioral health, and post-acute care partners.
- Develop a rolling 7-day discharge forecast to anticipate bottlenecks.
- Establish rapid psych diversion pathways, including tele-BH backup and sitter alternatives.
- Add boarding KPIs to executive dashboards (e.g., ED LOS ≤8 hrs; boarding for older adults ≤3 hrs).

Executive Checklist: Priorities

Time Frame	Actions
Today	Validate IPPS FY 2026 financial impacts; assign OPPS/PFS comment responsibilities and deadlines.
This Week	Scrub price transparency files; run CA SB 525 labor cost model (if applicable).
Next 30 Days	Launch ED capacity workflows, boarding dashboards, and 7-day discharge forecasts.