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Association Comments on 2019 Medicare OPPS Proposed Rule

In a Sept. 24 letter to the Centers for Medicare & Medicaid Services (CMS) on the calendar year (CY) 2019 Outpatient Prospective Payment System (OPPS) proposed rule, America’s Essential Hospitals urged the agency to reverse policies that will result in significant funding cuts to essential hospitals and hinder access to care.

As proposed, the rule would extend site-neutral payment cuts under section 603 of the Bipartisan Budget Act of 2015 (BBA) to certain services at excepted off-campus provider-based departments (PBDs) and expand a policy that drastically reduces Medicare Part B reimbursement for drugs purchased through the 340B Drug Pricing Program. The proposal also includes changes to outpatient quality reporting provisions and requests for information on interoperability and transparency.

In its comments, America’s Essential Hospitals urges CMS to:

  • reverse its Part B drug payment policy for hospitals participating in the 340B program;
  • withdraw its proposal to reduce payments for separately payable drugs administered at non-excepted PBDs;
  • withdraw its proposal to reduce payments for clinic visits at excepted off-campus PBDs;
  • implement section 603 of the BBA consistent with the legislative text to minimize the adverse effect on patient access;
  • account for the unique health and social challenges of communities served by essential hospitals and preserve adequate reimbursement rates for essential hospitals’ excepted and non-excepted PBDs;
  • continue to refine the Hospital Outpatient Quality Reporting Program measure set;
  • ensure its comprehensive APC policy does not disproportionately impact hospitals treating more diverse and clinically complex patients;
  • remove the communication about pain questions from the Hospital Consumer Assessment of Healthcare Providers and Systems Survey measure under the Hospital Inpatient Quality Reporting Program;
  • address cost and payment barriers to the use of non-opioid alternatives;
  • ensure any efforts to improve transparency account for existing reporting requirements, as well as sociodemographic variation among patients served by essential hospitals, and do not add administrative burden to providers; and
  • encourage improved communication between providers and patients, as well as improved care transitions, without putting further burden on essential hospitals by requiring additional information exchange through Conditions of Participation

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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