Comments to CMS requested on final rule for OPPS/ASC payment systems

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SDAHO joins with the American Hospital Association (AHA) in urging members to submit comments to the Centers for Medicare & Medicaid Services (CMS) on the agency’s calendar year 2017 outpatient prospective payment system/ambulatory surgical center (OPPS/ASC) final rule.

The rule issued Nov. 1 establishes the site-neutral payment rates for certain off-campus provider-based hospital outpatient departments (HOPDs). It implements the site-neutral provisions of Section 603 of the Bipartisan Budget Act of 2015. The act requires that, with the exception of dedicated emergency department (ED) services, services furnished in off-campus hospital PBDs that began furnishing covered outpatient department services on or after Nov. 2, 2015, no longer be paid under the OPPS. Instead, hospitals will be paid under the physician fee schedule (PFS) at newly established rates for these services.

We appreciate that the final rule appropriately recognizes that providing no payment to new off-campus hospital provider-based departments (PBDs) for the services they provide to patients was an untenable policy. The new payment level will be further evaluated to ensure that it is fair and reasonable.

Also, we applaud the modifications CMS made to its proposal to allow existing off-campus PBDs to expand their services to meet the changing needs of their patients and communities without being penalized. However, with the provision that penalizes hospitals that need to relocate their PBDs, CMS continues to ignore the need for hospitals to modernize existing facilities so that they can provide the most up-to-date, high-quality services to their patients in locations that meet patients’ needs.

We have requested immediate action on these priority areas be addressed during the current lame duck session of the 114th Congress. The final rule will take effect Jan. 1, and CMS will accept comments through Dec. 31.