1. Macro forces are creating a degree of pressure across Medicare reimbursement for PPMs; however, the pressure in 2023 is significantly muted thanks to congressional intervention.
2. CMS’ updates to clinical labor pricing continues to create winners and losers through 2025, with the impact varying by specialty and site-of-service.
3. Reimbursement in ASCs continues to trend positively, but 2024 rulemaking will be crucial in determining if CMS will protect these tailwinds long-term.
4. Farragut expects near-term PFS rulemaking to create new waves of macro pressure for the mid-2020s, which will necessitate another round of congressional intervention or cuts between -3% to -12%, depending on the specialty.
5. As investment in PPMs mature and CMS enacts more nuanced approaches to reimbursement, investors will need to pay closer attention to strategy within a sector – including site-of-service, geography, and service lines – rather than thinking of whole sectors as positive or negative.

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