On July 25, The Centers for Medicare and Medicaid Services (CMS) proposed several changes to the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System, which, if finalized, would generally be credit negative for both not-for-profit and for-profit hospitals. Changes include: (1) site neutral clinic visits, (2) expansion of 340B policy changes to off-campus departments of hospitals, and (3) adding certain nonsurgical procedures as covered procedures at ambulatory surgical centers. While on their own, these proposed changes would not be material to overall sector credit quality, the effects would vary by hospital. In general, the proposal to move certain cardiac procedures to ASCs, if finalized and if adopted by clinicians, would likely have the broadest and most significant effect on the hospital sector. Additionally, to the extent that commercial payors follow suit, each of these changes would have more meaningful effects…..