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Association Submits Comments on CY 2015 OPPS Proposed Rule

America’s Essential Hospitals submitted comments Sept. 2 to the Centers for Medicare & Medicaid Services (CMS) on the calendar year (CY) 2015 Outpatient Prospective Payment System (OPPS) proposed rule.

In its comments, the association urged CMS to revise its comprehensive ambulatory payment classifications (C-APCs) proposal to account for patient complexity, so hospitals treating sicker patients and performing more resource-intensive procedures are not adversely impacted. The association also opposed CMS’ proposal to require hospitals to report a claims-based Healthcare Common Procedure Coding System modifier for every outpatient service provided in off-campus provider-based departments. Instead, the association recommended CMS create a workgroup that includes the hospital industry to determine how best to collect data on care provided in hospital outpatient departments.

Please contact Xiaoyi Huang, JD, director of policy, at or 202.585.0127 with questions.


About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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