If you spent an afternoon at a hospital-based clinic this month, you might be surprised to find three or four separate envelopes in your mailbox. As of January 1, 2026, a growing number of hospital departments are billing separately for services that were previously bundled into a single “global” charge. This “unbundling” trend is a direct reaction to the 2026 Hospital Outpatient Prospective Payment System (OPPS) Final Rule, which expanded “site-neutral” payment cuts. By separating “Professional” fees (the doctor’s time) from “Technical” or “Facility” fees (the room and equipment), hospitals are attempting to protect their revenue as Medicare slashes reimbursements for off-campus outpatient departments by as much as 60%.
The Rise of “Provider-Based” Billing
The primary driver of hospital departments billing separately is the designation of clinics as “Provider-Based Departments” (PBDs). Under this model, the clinic is technically considered part of the hospital, even if it is miles away. This allows the hospital to send two bills: one for the “Professional Component” and another for the “Technical Component.” Starting in 2026, major insurers like UnitedHealthcare are enforcing strict “Modifier PO” policies that require these off-campus sites to identify themselves, often triggering separate facility fees that apply directly to your deductible.
1. Oncology and Infusion Centers
In 2026, oncology is the “ground zero” for separate billing. CMS has finalized a site-neutral rate for drug administration in off-campus hospital departments, paying only 40% of the previous rate. To compensate, many centers are unbundling the “Nursing Care” and “Pharmacy Handling” fees from the actual drug cost. Patients receiving chemotherapy now often receive separate bills for the oncologist’s consultation, the nurse who administered the IV, and the “Facility Fee” for the infusion chair itself.
2. Nuclear Cardiology and Stress Testing
Nuclear medicine is facing a significant “reassignment” in 2026. The American Society of Nuclear Cardiology (ASNC) has warned that stress tests (CPT 93017) are seeing a 28% cut in facility payments. In response, hospitals are unbundling the Radiopharmaceutical (the imaging tracer) from the procedure. Under new 2026 rules, certain “separately payable” drugs are billed on their own, often resulting in a high-cost pharmacy bill that is separate from your cardiology appointment.
3. Physical and Occupational Therapy
As hospitals transition their therapy centers to “Hospital Outpatient Departments” (HODs), separate billing is becoming the norm. For a 2026 therapy session, you may receive a “Professional” bill for the therapist’s manual work and a separate “Facility” bill for the use of the gym equipment and supplies. These facility fees are often subject to your deductible, while the therapist’s fee might only require a standard copay, leading to a much higher total cost than a private practice visit.
4. Wound Care Centers
Wound care is undergoing a major coding overhaul in 2026. CMS has finalized a plan to unpackage skin substitute products from the application service. This means if you receive a skin graft, you will get one bill for the doctor’s surgical work and a second, much larger bill for the “Product” itself. This unbundling is designed to “reward efficiency,” but it makes it much harder for patients to predict their total out-of-pocket costs before the procedure.
5. Radiology and Advanced Imaging
While many radiology services were already billed separately, 2026 has brought a new “Global Component” split. If you get an MRI at a hospital-owned center, the Professional/Technical Component Policy now requires the radiologist to submit a separate report for their “Interpretation” (Modifier 26) to be considered for reimbursement. If the hospital fails to sync these claims, the patient may receive a bill for the “technical use” of the machine while the “doctor’s reading” remains stuck in an insurance pending loop.
6. Sleep Study Labs
Sleep labs are increasingly moving to a “split-billing” model in 2026 to manage the rising costs of overnight monitoring staff. You may receive a bill for the “Technical Monitoring” performed by the technician during the night and a separate “Professional Consultation” bill from the sleep physician who reviews the data the next morning. These departments often use different Tax ID numbers, meaning you must meet two separate “In-Network” verifications for a single night’s stay.
7. Laboratory and Pathology
Starting April 1, 2026, UnitedHealthcare will implement automated post-service enforcement for laboratory services. This is pushing hospital labs to bill separately for “Specimen Collection” (the blood draw) and “Pathology Interpretation.” If your blood is drawn at a clinic but sent to the main hospital lab, you will likely see a “Collection Fee” from the clinic and a “Processing Fee” from the hospital, each potentially subject to different coinsurance rates.
How to Audit Your “Mult-Bill” Visit
The transition of hospital departments billing separately is a confusing by-product of “site-neutral” payment reforms. While the goal of these reforms is to lower the total cost of care for the government, the immediate result for the patient is a complex web of facility fees and unbundled charges. To protect yourself, always ask: “Is this facility a ‘Provider-Based Department’ of the hospital?” If the answer is yes, be prepared for at least two separate bills. Use your 2026 Price Transparency tools to check the “Median Allowed Amount” for both the professional and facility components before you agree to a visit.
Did you receive multiple bills for a single 2026 check-up or lab visit? Leave a comment below.
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