CHA News

CHA Comments on CY 2022 OPPS Proposed Rule

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CHA has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the calendar year 2022 outpatient prospective payment system (OPPS) proposed rule

In the letter, CHA: 

  • Opposes CMS’ existing and proposed payment methodology for 340B-purchased drugs and requests that CMS restore payment for separately payable drugs acquired through the 340B program at average sales price plus 6% in a non-budget neutral manner  
  • Strongly opposes increasing the penalties related to the hospital price transparency requirement, as CHA believes it is premature to assert that the existing penalties are insufficient to compel compliance and resources necessary to implement the requirements because hospitals have been focused on responding to the COVID-19 public health emergency.  
  • Encourages CMS to delay the start of the radiation oncology (RO) model until Jan. 1, 2023, to allow time for health systems to upgrade their IT systems to participate. CHA also asks the agency to reduce the model’s discount rate. Given the capital-intensive nature of RO services, CHA is concerned that an inappropriately inflated discount rate will result in longer wait times and reduced access to RO services for all patients. 
  • Strongly supports CMS’ efforts to mitigate the impact of COVID-19 on OPPS rate setting by using 2019 Medicare Provider Analysis and Review data and federal fiscal year 2018 Hospital Cost Report Information System data to establish the relative weights and calculate the fixed loss outlier threshold  
  • Urges CMS to address several operational questions and concerns related to reporting on the proposed COVID-19 Vaccination Coverage Among Health Care Personnel quality measure, including reducing duplicative reporting requirements and revising measure specifications to address booster shots and exemptions for sincerely held religious beliefs