The Outpatient Quarter Opens Thursday Without a Rate Book
CMS has issued 253 transmittals this year, including seven that tell contractors how to handle the October 1 quarter. The October OPPS update, the October ASC update and the October outpatient code editor are not among them, and 45 new HCPCS codes go live Thursday, three of which have no published price anywhere. Eleven of the last twenty-one outpatient instructions already reached contractors after the quarter they govern had started, so this is closer to the pattern than to an exception.
On Thursday morning a hospital outpatient department will bill C9312 for the first time. Nobody outside CMS can tell it what that line pays.
The code is real and published. CMS put it in the October 2026 Alpha-Numeric HCPCS file with a long descriptor that reads, in full, "Injection, trabectedin (apotex), not therapeutically equivalent to j9362, 0.01 mg."
That descriptor closes off the one shortcut a biller would reach for, which is pricing the thing off the permanent trabectedin code.
And the document that assigns it a status indicator and an APC does not exist.
What Shipped and What Didn't
We parsed the CMS 2026 transmittal table in full this morning. 253 unique transmittals carry a 2026 issue date, and the newest of them is R13968OTN from September 24.
Seven of those 253 are the quarterly instructions that govern the October 1 quarter, and all seven have been out for a while (chart below). The October HCPCS quarterly update reminder went out 127 days ahead. The October ASP Part B drug pricing file instruction went 93 days ahead. The physician fee schedule database update went 35. The SNF consolidated billing update, the last one to ship, went 30.
Search every 2026 title for "Outpatient Prospective Payment System", "Ambulatory Surgical Center" and "Integrated Outpatient Code Editor" and you get twelve rows. The newest in each of the three families is July.
There is no October 2026 OPPS update. No October 2026 ASC payment system update. No October 2026 I/OCE specifications.
The quarterly addenda page agrees. As of this morning it still tops out at "July 2026 - updated July 21, 2026" for Addendum A, Addendum B and Addendum Q, and the ASC payment rates page still tops out at the July file.
So does First Coast, whose own OPPS addendums page for Florida hospitals is dated July 6 and points providers at MM14477 and I/OCE version 27.2.
Three Codes With Nowhere to Get a Price
The October HCPCS file adds 45 codes with an effective date of October 1 and terminates 15 on September 30. We covered those terminations and the billing-unit shifts twelve days ago, when the file first posted.
CMS has refreshed the file since, on the 23rd, and both counts held.
What has changed is which half of the quarter is missing.
The drug half arrived. The October ASP payment limit file is posted, stamped "Effective October 1, 2026 through December 31, 2026", with 919 priced rows.
Fifteen of the 45 new codes are in it. J9362, trabectedin at 0.01 mg, prices at $41.844 a unit, which is $4,184.40 a milligram.
Three of the 45 are not in it, and would not be. C-codes get their rates through the OPPS update, which is also why the four C-codes dying on September 30 never appeared in a July ASP file. The three going live Thursday are:
- C9311, eplontersen, 1 mg
- C9312, trabectedin (apotex), 0.01 mg, the one whose descriptor forbids the crosswalk
- C9313, pivekimab sunirine-pvzy, 0.01 mg
All three are flagged YY in the ASC payment group field, so surgery centers are holding the same bag. And 21 of the 45 new codes carry that flag.
The rest of this brief is for subscribers.
The impact tables, the code-level detail, and the rest of the analysis sit past this line.
$50 a month, or $500 a year.
Already a subscriber? Sign in