The Centers for Medicare & Medicaid Services recently released its proposed rule for changes to the Medicare outpatient prospective payment system. The rule proposes to implement the site-neutral provisions of Section 603 of the Bipartisan Budget Act of 2015. In its advisory to members, the American Hospital Association (AHA) expressed its dismay by the short-sighted proposals, which do not take advantage of flexibility provided by Congress. While Congress cut payments for newly established hospital-based clinics, it provided for flexibility in certain circumstances. For example, the law allows for payment for ancillary services provided in these clinics. In contrast, the agency is proposing that these clinics would get no Medicare payment. In addition, the agency would not allow exemptions for clinics that relocate or rebuild their outpatient facilities in order to provide needed updates.
WSHA has drafted a letter supporting AHA’s comments. Comments on the proposed rule are due by Sept. 6. We encourage hospitals to submit their own comments. Please send us a copy of your comments and let us know if you have suggestions on our proposed letter. (Andrew Busz)