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Today, the Centers for Medicare & Medicaid Services (CMS) issued its final rule updating the outpatient prospective payment system (OPPS) for calendar year (CY) 2019, which also includes payment updates for ambulatory surgical centers. Despite strong opposition from CHA and the hospital field, CMS finalized an expansion of its site-neutral payment policies.
Effective Jan. 1, 2019, CMS will implement two of the three proposed site-neutral payment provisions: a 60 percent reduction of payments for clinic visits furnished in excepted off-campus provider-based departments (PBDs) phased in over two years, and an extension of 340B Drug Pricing Program payment cuts to non-excepted off-campus PBDs. In a change from the proposed rule, CMS will not apply the site-neutral payment rate to new services provided in excepted PBDs that opened on or after Nov. 1, 2015.
CHA is extremely disappointed in the expansion of these site-neutral policies and believes that CMS has misconstrued Congress’ intent in implementing the cuts. CHA will support the American Hospital Association’s efforts as it seeks a legal remedy for this punitive policy. CHA will also call upon congressional leaders to protect the sick and the elderly who rely on hospital outpatient clinics for medical care.
The final rule includes numerous payment, policy and quality provisions. More information is available in CMS’ fact sheet and press release. CHA will provide members with a detailed summary in the coming weeks; key provisions are highlighted below:
- OPPS Payment Update: CMS finalized an OPPS update of 1.35 percent for CY 2019. This reflects a hospital market basket increase of 2.9 percent, minus the productivity and Affordable Care Act-mandated adjustments (0.8 and 0.75 percent, respectively). After accounting for other changes in the final rule, CMS estimates this will result in an increase of $440 million in OPPS payments compared to CY 2018.
- Partial Hospitalization Program (PHP): As finalized in the CY 2017 OPPS final rule, CMS continues to pay for PHP services using a single, blended payment rate for either hospital-based or community mental health center (CMHC) settings. CMS notes that it neglected to include new, revised and deleted CY 2019 Category I and III CPT codes related to these services in the PHP section of the CY 2019 OPPS proposed rule. As a result, the final rule includes proposals to delete six existing codes from the PHP allowable code set for CMHC and hospital-based PHP services, and replace them with nine new codes beginning Jan. 1, 2019. CMS says it is soliciting comments on these proposals, due Dec. 3, and will seek to finalize the proposal in its CY 2020 OPPS final rule.
- Outpatient Quality Reporting (OQR) Program Measures: As part of its meaningful measures initiative, CMS removes eight measures from the OQR program, one beginning with the CY 2020 payment determination and seven beginning with CY 2021.
- Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS): As required by the recently signed Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, CMS finalizes the removal of three “communication about pain” questions from the HCAHPS survey under the Inpatient Quality Reporting Program. The removal of these questions is effective with October 2019 discharges, for the federal fiscal year 2021 payment determination and subsequent years — earlier than proposed.
