CHA submitted comments on the calendar year (CY) 2023 outpatient prospective payment system (OPPS) proposed rule.
In the letter, CHA raises concerns about the inadequate proposed market basket update and asks CMS to use alternative sources of data that better reflect input price inflation experienced by providers to calculate the CY 2023 market basket update. CHA also asks CMS to use its existing authority to eliminate the productivity adjustment from the market basket update calculation for any year impacted by the COVID-19 public health emergency. Additionally, CHA asks CMS to calculate the outlier threshold using an average of the outlier-fixed-loss amounts calculated with and without COVID-19 cases in the fiscal year 2021 data.
CHA also provides detailed comments on the agency’s proposals, including:
- 340B separately payable Part B drugs and biosimilar biological products
- Exemption of some hospitals from the site-neutral clinic visit payment policy
- Creation of an add-on payment for domestically manufactured N95 respirators
- Reduction in payment for partial hospitalization programs
- Establishing payment under the OPPS for remote mental health services furnished in the patient’s home
- Returning to voluntary reporting status of Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery (OP-31) in the Outpatient Quality Reporting Program
- The addition of new services to the list of those subject to prior authorization
CHA thanks members for their feedback, which informed comments.