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CHA has submitted the attached letter on the calendar year (CY) 2019 physician fee schedule (PFS) and quality payment program (QPP) proposed rule, providing comments on many of the provisions that are significant to hospitals and the physicians who provide care in hospitals. This includes CMS’ proposal to maintain a payment rate of 40 percent of outpatient prospective payment system (OPPS) rates for items and services furnished at certain off-campus hospital outpatient provider based clinics, as required by Section 603 of the Bipartisan Budget Act of 2015. CHA is disappointed that the agency continues to ignore the significant differences in regulatory requirements and responsibilities of the hospital outpatient department in providing health care services to Medicare beneficiaries, and urges the agency to refine its methodology for determining the rate. CHA believes a more robust analysis would support a payment rate of 65 percent of the OPPS rates.
CHA also comments on CMS’ proposal to reduce documentation requirements for evaluation and management (E/M) visits while collapsing payments for Level 2 through Level 5 E/M visits into a single blended payment rate. While supporting a number of the proposals that would reduce documentation burden, CHA urges the agency to withdraw its payment proposal and engage stakeholders to address the outdated coding system and improve payment accuracy in the future.
CHA 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 the agency to exempt hospitals from reporting appropriate use criteria (AUC) consultation on the facility claim; and does not support the proposal to remove Medicare Advantage payments from the “majority of Medicare revenues” threshold calculation in determining applicable laboratory status for reporting certain private payer information.
CHA supports CMS’ proposals to pay for physicians’ use of communication technology-based services, including virtual check-ins, store-and-forward evaluations and interprofessional consultations, and urges the agency to consider increased payment to recognize the important role these services play in effectively managing patients. CHA also strongly supports CMS’ proposal to discontinue the functional reporting requirements for therapy services, and applauds the agency’s efforts to reassess the value of the current reporting requirements and data collection, as well as to make changes that will reduce administrative burden.
Finally, CHA provides comments on a number of provisions related to the QPP, including requirements for the 2019 performance year of the Merit-Based Incentive Payment System. Notably, CHA supports CMS’ proposed expansion of a facility-based scoring option that will better address clinicians who primarily provide inpatient care but spend little — yet significant — time providing care in other settings, such as observation units or same-day surgical units based in hospitals.
