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Association Highlights Underserved in 2016 OPPS Comments

America’s Essential Hospitals called on the Centers for Medicare & Medicaid Services (CMS) to consider the unique challenges inherent in caring for the nation’s most vulnerable patient populations in finalizing its payment policies under the calendar year (CY) 2016 Outpatient Prospective Payment System (OPPS) proposed rule.

In our comments, we asked CMS to finalize its proposed exception to the two-midnight policy, whereas inpatient stays lasting fewer than two midnights could be appropriate for Medicare inpatient reimbursement based on physician judgement. We also urged CMS to account for patient complexity in its comprehensive ambulatory payment classification (C-APC) methodology, so hospitals treating sicker patients and performing more resource-intensive procedures are not adversely impacted. We opposed the use of a claims-based modifier to identify services adjunctive to comprehensive services.

Furthermore, we objected to the reduction in outpatient payment rates that CMS proposes as a result of the agency’s erroneous CY 2014 calculations of laboratory packaging. We also commented on the Outpatient Quality Reporting (OQR) Program. We support CMS’ proposed removal of one measure not aligned with current clinical guidelines related to computed tomography (CT) use in the emergency department, but urged CMS to refine a care transitions measure before including in the OQR Program.

Contact Beth Feldpush, DrPH, senior vice president of policy and advocacy, at or 202.585.0111 with any questions.


About the Author

Maryellen Guinan is a principal policy analyst at America's Essential Hospitals.

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