Medicare may soon allow hundreds of additional procedures to move out of the inpatient hospital setting. That does not mean every procedure will leave the hospital, or that every medical building can accommodate surgical care. It does mean healthcare organizations, property owners and investors should take a closer look at whether Tampa Bay outpatient real estate can support the next phase of care delivery.

In July, the Centers for Medicare & Medicaid Services released its proposed 2027 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System rule. CMS proposes continuing a three-year phaseout of the inpatient-only list, which identifies procedures Medicare will reimburse only when performed in a hospital inpatient setting.

For 2027, the agency proposes removing hundreds of services from that list. The affected clinical families include digestive, endocrine, respiratory, urinary and several other specialties. CMS also proposes adding 618 procedure codes to the Ambulatory Surgical Center Covered Procedures List. These additions include codes recommended by stakeholders and codes connected to services proposed for removal from the inpatient-only list.

These policies are not final. They also do not make every patient or facility appropriate for outpatient surgery. Clinical judgment, patient condition and Medicare coverage requirements still matter. But the proposal gives Tampa Bay healthcare organizations a reason to examine their real estate before the rules take effect.

Key Takeaways

• CMS proposes adding 618 procedure codes to the Ambulatory Surgical Center Covered Procedures List for 2027.
• A procedure becoming eligible for outpatient care does not make an ordinary medical office suitable for surgery.
• Tampa Bay providers and property owners should evaluate utilities, patient flow, parking, recovery space and licensing before committing to a location.

More eligible procedures could change space demand

Removing a service from the inpatient-only list allows Medicare to pay for it in a hospital outpatient department when outpatient care is clinically appropriate. Placement on the Ambulatory Surgical Center Covered Procedures List is a separate determination that permits Medicare payment in a qualified ambulatory surgical center.

That distinction matters for real estate planning. Some procedures may move from inpatient units to hospital outpatient departments. Others may be suitable for freestanding ambulatory surgical centers. Certain services will continue to require the staffing, technology and emergency support available at a hospital.

If CMS finalizes the change, health systems and physician groups will have more choices about where they provide care. That can create demand for new facilities, expansion within existing centers or conversion of other commercial space.

The opportunity is not limited to surgery center operators. Medical office landlords may see interest from specialists seeking procedure space near established referral networks. Investors may encounter properties whose value depends on whether they can support more intensive clinical use. Health systems may reconsider which services need to remain on a hospital campus.

An outpatient facility needs more than an exam room

Outpatient surgical space has different physical and operational demands from a standard physician office. A building that works well for primary care may require major changes before it can support procedures, recovery and regulated clinical operations.

Electrical capacity is one early concern. Surgical equipment, sterilization systems, imaging technology and backup power requirements can place demands on a building that were never anticipated in its original design. Mechanical systems may need to maintain specific air pressure, filtration, temperature and humidity conditions.

Patient flow also affects the floor plan. A functioning facility may need separate paths for patients, clinical staff, supplies and waste. Preoperative and recovery areas require privacy, visibility and enough room for staff to work safely. Some procedures need larger rooms, medical gas systems or space for specialized equipment.

Parking deserves more attention than a standard ratio calculation. Surgical patients often arrive with a family member or caregiver who remains on site. Appointment schedules can create concentrated arrival and departure periods. Staff parking, patient drop off and accessible routes all affect whether the location works in daily practice. Healthcare Realty Group’s guide to five medical office site-tour red flags explains why these operational details should be evaluated in person.

A property can have enough square footage and still be a poor fit.

Florida licensing and life safety requirements shape feasibility

In Florida, an ambulatory surgical center must be licensed through the Agency for Health Care Administration. The agency defines an ASC as a licensed facility, separate from a hospital, whose primary purpose is providing elective surgical care.

Licensure brings requirements that ordinary office users may never encounter. Florida requires periodic Life Safety Code inspections for ambulatory surgical centers. Facility changes can require applications and regulatory review. Emergency management plans must also receive annual approval from the applicable county emergency operations center.

Those requirements can affect both cost and timing. A proposed conversion may require architectural plans, engineering work, construction review, fire protection improvements or changes to building systems. Zoning and certificate of occupancy questions can surface before clinical licensing even begins.

A lease should reflect those realities. Providers may need sufficient time for design, permitting, construction and licensing before rent obligations fully begin. Tenant improvement allowances must account for the intensity of the buildout. Responsibility for utility upgrades, code compliance and restoration at the end of the lease should be clear.

Owners considering a medical conversion should complete a physical and regulatory feasibility review before marketing a building as ASC ready. That phrase implies much more than proximity to a hospital or the presence of medical tenants.

Conversion risk should be tested before the lease is signed

Converting retail, office or existing medical space can be faster than ground-up development in some cases, but the existing structure creates limits.

Ceiling heights, column spacing and utility locations can restrict room layouts. The building may not have enough electrical service or generator capacity. Plumbing and drainage can be expensive to relocate. Fire separation, sprinkler coverage and patient evacuation requirements can change the scope of work.

The surrounding site matters too. An attractive building may sit too far from referral sources, lack convenient access or have insufficient parking during peak hours. A second-generation medical office may reduce some construction costs, but prior medical use does not prove that it can support an ambulatory surgical center.

The proper evaluation starts with the intended clinical program. The project team can then test the building against the procedures, equipment, staffing, recovery model and regulatory requirements involved. Starting with an available property and forcing the clinical program into it reverses that logic.

Tampa Bay planning should begin before the rules are final

CMS has proposed a 2.4 percent payment update for qualifying ambulatory surgical centers in 2027, along with the expansion of the covered procedures list. Final policies may differ from the proposal, and reimbursement alone will not determine whether a new facility succeeds.

Local planning should also consider physician alignment, referral patterns, payer mix, patient access and competition. In a region as geographically dispersed as Tampa Bay, a site that works for patients in Brandon may not serve the same strategic purpose as one in Clearwater, Wesley Chapel or South Tampa.

Providers evaluating expansion should identify which procedures could move, estimate realistic case volume and determine whether an existing facility can support the program. Landlords should understand the cost and regulatory consequences before promising specialized space. Investors should test whether projected demand is supported by a defined operator and clinical use.

The outpatient shift is creating more choices, but those choices require disciplined real estate analysis. Healthcare Realty Group’s healthcare real estate services help providers, owners and investors evaluate properties in the context of clinical operations, regulation and long-term strategy.

Frequently Asked Questions

What is Medicare’s inpatient-only list?

It identifies procedures Medicare generally pays for only in an inpatient hospital setting. CMS is proposing to continue phasing out the list through 2027.

Can any medical office become an ambulatory surgical center?

No. The property must support the clinical program and satisfy licensing, life safety, utility, recovery, patient flow and emergency planning requirements.

Should a provider lease space before the 2027 rule is final?

A provider can begin feasibility work now, but commitments should account for regulatory uncertainty, licensing, construction costs and the needs of the planned procedures.