Medicare often pays more for the same service when administered in a hospital outpatient department (HOPD) than an independent doctor’s office. This Paragon Pic shows that the disparity between the two sites of service is wide and growing.
We analyzed data for 4,281 services across HOPDs and physician offices and found that Medicare’s site-of-service payment gap has grown sharply. In 2011, HOPDs received 109 percent more than physician offices for the same services on a volume-weighted basis; by 2026, they received 247 percent more. In nominal dollar terms, average HOPD payments rose from $258 to $355, while physician-office payments fell from $123 to $102. If this trend continues through 2035, HOPDs will receive $430 on average while physicians’ offices will only receive $92–a 369 percent advantage for hospital-based care for services that are virtually indistinguishable.
This gap is the result of two separate payment systems that Medicare uses to pay for services. The first is the Outpatient Prospective Payment System (OPPS), which ostensibly compensates hospitals for the capital and labor expenses involved in providing services. The second is the Physician Fee Schedule (PFS), which pays physicians for services rendered, regardless of where that service is performed. A service that is performed in a HOPD by a physician will receive two payments: an OPPS payment for the hospital—often called a “facility fee”—and a PFS payment for the physician. Meanwhile, that same service performed by a physician in an independent physician’s office will only receive one payment from the PFS. Medicare pays a higher non-facility PFS rate than the facility PFS rate because the physician incurs practice expenses that the hospital otherwise bears. However, the OPPS facility fee that hospitals receive is generally equal to or larger than the PFS rate. Because most hospital-employed physicians are salaried, hospitals usually receive both the OPPS and PFS payments. As demonstrated in the Paragon Pic, the combined hospital and physician payment typically exceeds the office-based physician payment by a wide margin.
Medicare awards this extensive reimbursement for outpatient procedures even though outpatient facilities are relatively low-cost compared to inpatient facilities. The Medicare program functionally recognizes this fact in the slightly larger PFS rate paid to independent physicians, who must maintain a facility that covers the same services as a HOPD. This payment differential is effectively a subsidy benefiting hospitals that inflate operational costs and reducing their incentives to improve efficiency. To make matters worse, Medicare automatically adjusts the OPPS facility fee for inflation but does not do the same for PFS payments to physicians due to the different designs of the payment systems.
These payment differentials create significant distortions, including incentives for vertical consolidation. They also mean more costs for taxpayers, and the distortions and waste will only grow the longer Congress allow them to persist. Introducing a Medicare site-neutral payment reform would reduce incentives for hospitals to acquire physician practices and lower costs for patients and taxpayers.










