WSHA Provides Draft Comments on Medicare Outpatient Proposed Rule

September 9, 2022

Comments on the Centers for Medicare and Medicaid Services (CMS) proposed outpatient rule are due September 13. WSHA will submit comments by the deadline and has provided a draft of its comments to member hospitals. WSHA’s letter includes comment on the following areas:

  • Proposed marketbasket and productivity adjustments
  • 340B hospital payments
  • Site-neutral clinic visit cuts
  • Hospital outpatient outlier payments
  • Payment adjustments for N95 respirators
  • Coding for reporting discarded amounts of single use drugs
  • Rural Emergency Hospitals

Member hospitals wishing to comment are encouraged to draft and submit their own comments using the draft language provided. We strongly encourage adding information on how the proposed changes would specifically impact their hospital outpatient services. Members hospitals that have questions or additional items they would like included in our comments should contact Andrew Busz at
(Andrew Busz,


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