WSHA opposes cuts to 340B payments, hospital clinic cuts; supports RHC codes for behavioral health integration

September 13, 2017

WSHA submitted a comment letter strongly opposing provisions in CMS’s proposed outpatient rule that would reduce by 25 percent payments for outpatient drugs provided by 340B eligible hospitals. In its letter, WSHA commented that the proposed reduction exceeds CMS’s authority and that the program is functioning as Congress intended, to allow eligible hospitals to stretch federal resources to reach more eligible patients and provide more comprehensive services.

On a related note, a bi-partisan group of U.S. Representatives are collecting signatures for a “Dear Colleague” letter urging the Centers for Medicare & Medicaid Services (CMS) to rescind its proposal to reduce Medicare Part B payment for drugs acquired through the 340B Drug Pricing Program.  WSHA will be encouraging our Congressional delegation to sign on to the letter.

WSHA sent a separate comment letter opposing CMS’s proposal to further reduce payment for nonexempted services at off-campus hospital outpatient departments.  For calendar year 2017, CMS cut payments to newer off-campus hospital sites to 50 percent of the regular payment rate. For 2018, CMS proposes an additional 50 percent reduction, to 25 percent of the standard rate. WSHA commented that the proposed reduction goes far beyond Congress’ instruction that CMS develop a payment mechanism to provide comparable payment for hospital and similar services at independent clinics and facilities and the proposed reduction will limit access to needed services in many communities, which has the potential to drive up costs.  WSHA urged CMS to delay additional cuts to payment until a more thorough and accurate calculation of the payment between hospital and non-hospital services can be obtained and a thorough analysis of the dynamics contributing to the reduction of private practices is completed.

In the same letter, WSHA strongly supports CMS’s proposal to establish and increase Rural Health Clinic payment codes and for care coordination services, particularly codes for use the psychiatric collaborative care model (CoCM). WSHA commented that the proposed payment outside of the encounter calculation will greatly enhance the sustainability and access to mental health services in rural communities and enhance efforts to integrate behavioral health services in primary care. (Andrew Busz,


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