Virginia site-neutral payments
Virginia's site-neutral payment debate isn't over yet. It's moving to the data. With the Commonwealth's report due December 1, hospitals have a window to understand their exposure, build their evidence, and prepare for the policy debate that may follow.
Virginia is evaluating claims data now, and the findings are due before the 2027 General Assembly convenes. Unlock Health can help hospitals and health systems model their exposure, assemble the evidence the Commonwealth's analysis may not capture, and build the advocacy strategy that follows.
What happened in Virginia
The Virginia General Assembly considered legislation on site-neutral payments and decided it needs more information. Instead, the 2026 session directed the Virginia Department of Health to evaluate the All-Payer Claims Database and its potential use for several policy purposes, including informing site-neutral payment policy. Findings are due December 1, 2026, and they could shape how the issue returns in the 2027 session.
That creates a window for hospitals and health systems to prepare that states like Indiana and Delaware did not have.
Read the enacted research legislationWhy site-neutral payment matters
Pay the same amount for the same service, wherever it occurs. It may be tidy as an accounting rule, but it sets aside most of the operating reality of hospital care. And the exposure is larger than a reimbursement reduction. The greater risk is a policy debate that opens with a simplified cost narrative hospitals then have to dislodge.
A procedure code describes the service, not the patient. Hospital outpatient departments treat higher-acuity patients who cannot be safely managed elsewhere.
Emergency, trauma, obstetric, and behavioral health capacity must be staffed around the clock, whether or not any single service line covers its cost.
EMTALA, licensure, accreditation, and reporting requirements apply to hospitals in ways they do not apply to independent sites of care.
Hospitals carry substantial Medicare, Medicaid, and uncompensated care volume. Commercial reimbursement does not sit alongside that mix by accident.
Pharmacy, imaging, laboratory, credentialed clinical teams, and redundant systems support the full range of hospital services.
In much of Virginia, the hospital is where certain services exist at all. Reimbursement changes show up first in the services hardest to sustain.
Claims data can show prices, utilization, and payment patterns. It cannot necessarily explain all the operational reasons behind them, and it cannot show what a change in reimbursement could mean for access in specific Virginia communities.
Hospitals have evidence the state database does not.
Start gathering it.
Model how different site-neutral scenarios could affect reimbursement, service lines, and organizational economics.
Identify data and real-world examples that demonstrate differences in patients, costs, capabilities, and access.
Translate hospital economics into arguments legislators, employers, community leaders, and patients can understand.
Determine who needs to understand the issue, what evidence will matter to them, and when engagement should begin.
Prepare scenarios and response strategies before the Department of Health releases its findings.
We've been thinking about this for years
Unlock Health has spent years studying site-neutral payment policy, hospital reimbursement, and the healthcare cost narratives that influence policymakers, employers, and communities. That work informs how we approach Virginia. The goal isn't to predict what the Commonwealth's report will say. It's to make sure hospitals are ready to influence what it comes to mean.
Understand the policy
Our 2025 report devoted an entire section to site-neutral payments, including the financial implications for hospitals, the differences among sites of care, and the likelihood that commercial payors would follow government payment policy. It also argued that providers need analytics, communications, and advocacy strategies to prepare for these changes.
Read the reportBuild the evidence
Kevin Thilborger examines the assumptions behind recent research blaming hospitals for rising healthcare costs and explains what those analyses leave out. That discipline matters in Virginia as the Commonwealth develops its own claims-based research: understand the methodology, develop evidence that supplies the missing context, and don't wait until someone else's interpretation becomes the accepted narrative.
Read the articleShape the narrative
Kevin's broader argument for why hospitals need to explain their economics before payors, policymakers, researchers, and other interested parties define the story for them. Advocacy and communication should begin while the evidence is being developed, not after the conclusions become headlines.
Read the perspectiveStart preparing your strategy
By December, Virginia hospitals should know their exposure, have their evidence, understand their stakeholders, and be prepared to respond. Tell us where your organization stands and we'll bring the analysis and advocacy experience to the conversation.