CHA has submitted the attached comment letter on the calendar year (CY) 2019 outpatient prospective payment system (OPPS) proposed rule. In reviewing the policy and payment proposals outlined in the proposed rule, CHA is concerned that the agency has taken steps that are not only unlawful, but threaten the financial stability of the hospital OPPS and, in turn, access to care for Medicare beneficiaries. In particular, CHA strongly opposes CMS’ proposals to expand site-neutral payment policies for off-campus provider-based departments (PBDs) and to expand payment cuts for non-excepted PBDs participating in the 340B Drug Pricing Program. In addition, CHA provides comments on a number of other proposed payment and policy provisions. Specifically, CHA:
Urges CMS to withdraw all three of its proposals to expand site-neutral payment policies in off-campus PBDs
Opposes CMS’ proposal to reduce payments for separately payable Part B drugs from wholesale acquisition cost (WAC) plus 6 percent to WAC plus 3 percent
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