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Ambulatory Surgery Center Feasibility Study

Feasibility studies for physician-owned, joint-venture and corporate ambulatory surgery centers, prepared for SBA 504, SBA 7(a), USDA Business and Industry and conventional construction loans.

Start a StudyFirst response within 12 business hours

From $7,900, fixed fee, quoted before the engagement starts. 9 to 16 business days, rush from 5 business days. Prepared to SBA SOP 50 10 8.1 and USDA 7 CFR Part 5001, with a contractual acceptance commitment written into the engagement letter. First response within 12 business hours.

MMCG Invest prepares the independent feasibility study for a new or expanding ambulatory surgery center, built on the sponsoring surgeons' case logs, the service area's surgical demand, the certificate of need status of the state and the CY2026 Medicare payment rules that are moving surgical volume out of hospitals. The study gives the lender and the CDC the volume, payer-mix and coverage evidence that a special-purpose surgical building requires.

The regulatory tailwind

Medicare certified 6,436 ambulatory surgery centers at the end of 2024, up 2.2% in a year and in line with the average annual growth of the previous five years; 248 centers opened and 108 closed or merged. The sector is 95.3% for-profit, 93.7% urban and 68% single-specialty, with gastroenterology and ophthalmology each about a fifth of all centers. The fastest-growing types are orthopedic single-specialty centers, up 18.9% in 2024, pain-and-orthopedics multispecialty centers, up 20.9%, and cardiology centers, up 6.3%. Medicare fee-for-service spending in the setting rose 13.0% to $7.5 billion.

The CY2026 OPPS and ASC final rule accelerates the shift. It raises ASC rates 2.6%, adds 276 procedures to the covered procedures list under revised criteria that treat the old exclusion rules as physician safety considerations, adds a further 271 codes coming off the inpatient-only list, and begins a three-year phase-out that eliminates the inpatient-only list on January 1, 2029. The ASC conversion factor of $56.32 against $90.97 for hospital outpatient departments means ASC rates run about 46% below hospital rates for most services, which is why payers and physician owners move cases. Total knee arthroplasty volume in the setting rose 27.6% in 2024, total hip arthroplasty 28.7%, and total shoulder arthroplasty became payable the same year. When physicians take an ownership stake, the share of their procedures performed in a surgery center rises about 22% within two years, and when a center enters a market without one, hospital outpatient surgery falls about 7%.

The study treats the expansion with discipline. The twenty most common procedures still make up about 68% of Medicare volume in the setting and cataract removal alone is 18%, so a feasibility model does not assume that several hundred newly payable codes produce cases at once. Volume comes from the sponsoring surgeons' logs, specialty by specialty, with total joints and spine first and cardiology later.

Certificate of need

Twenty-two states and the District of Columbia require a certificate of need for a surgery center, and the difference shows in supply: Maryland has 36 centers per 100,000 Part B beneficiaries while several certificate-of-need states have three or fewer. The 2023 to 2026 trend is to release surgery centers first. South Carolina removed surgery centers from review in 2023, North Carolina exempted centers in counties over 125,000 residents from November 2025, Tennessee exempts them from December 2027, Maine exempted most centers in 2026, and Georgia exempts physician-owned single-specialty centers. In the remaining certificate-of-need states, the approval is the gating item on the schedule, and the study documents the threshold, the review timeline and the competitive filings that can delay it.

Physician ownership and joint ventures

Most surgery centers are partly or wholly physician-owned, with distributions in proportion to ownership, and five corporate operators held stakes in 1,372 centers in 2024, about 21.5% of the sector, usually as a management partner alongside a physician majority or minority. Margins are the reason: Pennsylvania, the only state that collects surgery center cost data, reported a 29.5% operating margin for 2024 against a historical range of 22.3% to 25.6%. The ownership structure drives the financing path. A center owned by physicians and a corporate operator can use SBA or conventional financing; a center in which a nonprofit hospital system holds 20% or more is ineligible for SBA unless the system guarantees the loan and its receipts fit the size standard, which in practice sends hospital joint ventures to conventional capital.

SBA financing

A de novo surgery center is a startup in a limited purpose building, and under 13 CFR 120.910 that places the SBA 504 borrower contribution at 20% of project cost, with a 50% bank first lien and a 30% CDC debenture. An established operator building a new center contributes 15%, and refinancing of a limited purpose building also carries a 15% minimum. The CDC states in its credit memorandum whether the project is limited or special purpose, the lender orders a going-concern appraisal from a Certified General appraiser with recent experience on equivalent special-use property, and the feasibility study supplies the operating projections that appraisal and credit decision rely on. Standard 7(a) loans require 1.15 debt service coverage on a historical or projected basis. The 7(a) maximum is $5 million, the standard 504 debenture is $5 million, and combined 7(a) and 504 capacity rose to $10 million in July 2026, which places a two-to-three operating room center inside SBA limits and sends larger multispecialty projects to conventional or USDA Business and Industry financing in rural markets.

Program and cost

A single-specialty center typically runs 8,000 to 10,000 square feet with two to three operating rooms, and a multispecialty center 15,000 square feet or more; the sector averages about 2.7 operating rooms per center. Interior build-out of surgical space runs about $325 to $475 per square foot and ground-up construction $550 to $850 per square foot in 2026 contractor benchmarks, and equipment for two operating rooms runs about $750,000 to $1 million, so a 10,000 square foot center lands at roughly $1.7 million to $3.5 million per operating room all-in before land and soft costs. Lenders commonly underwrite 1,000 to 1,500 cases per mixed-specialty operating room a year, with gastroenterology and ophthalmology procedure rooms running far higher. MMCG treats those as planning conventions and builds the volume from the sponsoring surgeons' historical case logs, by procedure and by payer.

What the study contains

  • A service area from the sponsoring surgeons' patient origin and drive times, with population, age and insurance profile.
  • Surgical demand by specialty from use rates per 1,000 residents, reconciled to the surgeons' case logs and the hospital outpatient volume available to shift.
  • A verified census of competing surgery centers and hospital outpatient surgery departments, with specialties, operating room counts, ownership and certificate of need filings.
  • Payer mix and reimbursement by procedure, with the CY2026 covered list and the inpatient-only phase-out applied to the center's actual case mix.
  • Operating room count, hours, block scheduling, staffing and accreditation.
  • Certificate of need status, threshold and timeline.
  • The project cost estimate in MMCG's standard format and the proposed debt structure, including the 504 equity contribution.
  • A five-year pro forma, debt service coverage, break-even cases per operating room and sensitivity cases at reduced volume and reduced reimbursement.
  • A feasibility determination.

Model study

A full model study is published for this page: a de novo two-operating-room orthopedic and pain surgery center in a North Carolina county released from certificate of need review, financed under SBA 504 at 20% equity. SBA 504 Feasibility Study Case Study: A Two-OR Orthopedic and Pain Ambulatory Surgery Center in Leland, North Carolina, Feasible Conditioned on Surgeon Commitments

Frequently asked questions

How much equity does an SBA 504 surgery center project need?

At least 20% for a de novo center, because the business has operated for two years or less and the building is a limited purpose property, and at least 15% for an established operator building a new center, under 13 CFR 120.910.

How many cases per operating room does the study assume?

None by default. Lenders often use 1,000 to 1,500 cases per mixed-specialty operating room a year as a planning convention, and the study validates the number against the sponsoring surgeons' historical case logs by procedure.

Does the CY2026 rule mean a new center can count on the newly covered procedures?

It means more procedures are payable in the setting, not that volume follows automatically. Volume in the setting remains concentrated in a small number of codes, so the study models the newly covered procedures only where the sponsoring surgeons already perform them.

Can a surgery center joint venture with a hospital use an SBA loan?

Rarely. A nonprofit system owning 20% or more must guarantee the loan and its receipts count toward the size standard, which most systems will not or cannot meet. Hospital joint ventures are typically financed conventionally.

Which states have released surgery centers from certificate of need?

South Carolina in 2023, North Carolina for counties over 125,000 residents from November 2025, Maine in 2026, Tennessee from December 2027, and Georgia for physician-owned single-specialty centers. The study confirms the current status in the project's state.

Request a proposal

Send the site, the specialties, the number of operating rooms, the sponsoring surgeons and their current case volume, the ownership structure and the loan program. A senior analyst responds within 12 business hours with a fixed-fee proposal and a delivery date.

Request Feasibility Study Proposal

Contact MMCG Invest

Michal Mohelsky, J.D., Principal of MMCG Invest

Michal Mohelsky, J.D., FMVA

Principal in charge · MMCG Invest, LLC

Emailmichal@mmcginvest.com

Direct(628) 225-1110

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9 to 16 business days

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