Same Service, Different Setting: Understanding Site-Neutral Payments

by Chris Nichols
| Sep 22, 2026

The Big Picture

Hospitals and independent medical facilities may provide some of the same services—such as surgery, lab work and imaging—but they are built for fundamentally different purposes.

Hospitals and their outpatient departments are open 24 hours a day, seven days a week. They care for everyone, prepare for disasters and provide treatment regardless of a patient’s ability to pay. They also care for the sickest patients, who often need specialized staff, testing, equipment and backup systems.

Independent medical facilities play an important role in the healthcare system, but they generally operate limited hours, offer a narrower range of services and are not required to provide emergency or advanced care. The service may sometimes look the same, but the setting—and everything required to support it—is not.

What’s Happening

Congress is considering what are known as “site-neutral payments” as a way to lower medical costs. Under this approach, Medicare would pay hospitals the same rate as independent physician offices, labs, imaging centers or surgical centers for certain services, regardless of where patients receive that care.

On the surface, the concept sounds straightforward: the same payment for the same service. But that approach does not account for the additional responsibilities hospitals carry every day, including around-the-clock staffing, strict safety and regulatory requirements, emergency preparedness, advanced equipment and care for uninsured patients.

Why It Matters

Hospitals already face significant financial pressure. On average, they receive only 82 cents from Medicare for every dollar it costs to care for Medicare patients.

Further payment reductions could force some hospitals to scale back critical services or close outpatient clinics. The effects would be felt most acutely in rural and underserved communities, where patients often have fewer healthcare options and the loss of even one service can create a major barrier to care.

Studies estimate that site-neutral payments could result in more than $1 billion in lost hospital funding in Utah over 10 years. Those reductions could affect emergency care, cancer treatment, mental health services, surgery, imaging and other essential care that Utahns rely on.

The Bottom Line

Utahns depend on hospitals to be ready at all hours, every day—not only to provide routine services, but also to respond when patients face emergencies, complex illnesses or limited access to care.

Site-neutral payments are expected to be an important issue in the 2027 legislative session, with significant implications for hospital care and access across the state. As policymakers consider the issue, it is essential to recognize that the location of care is not merely a setting; it reflects the staff, infrastructure and public responsibilities required to keep critical healthcare services available to every community.