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 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
- Urges CMS to unpackage non-opioid pain management drugs in ambulatory surgical centers, as well as in hospital outpatient departments under the OPPS
- Supports the proposed removal of measures from the Outpatient Quality Reporting Program and urges CMS to take steps to accelerate its timeline for removal
- Encourages CMS to ensure coding, billing, cost reporting and payment decisions for chimeric antigen receptor T-cell (CAR-T) therapy are aligned and consistent, with appropriate guidance provided to ensure accurate and reliable reporting
- Opposes the creation of additional Medicare Conditions of Participation (CoPs) to require the electronic transfer of health information, and urges the agency to reject a piecemeal approach to CoP revisions that does not consider implications across the delivery system
CHA encourages members to share their comments with CHA. Comments on the proposed rule are due Sept. 24 by 2 p.m. (PT) and can be submitted at www.regulations.gov.