CHA News

CHA Submits Comments on Area Wage Index, Price Transparency Proposals in OPPS Proposed Rule

For CEOs, CFOs, government relations executives

This post has been archived and contains information that may be out of date.

CHA submitted comments on the calendar year (CY) 2020 outpatient prospective payment system (OPPS) proposed rule issued by the Centers for Medicare & Medicaid Services (CMS). Members are encouraged to use the letter, and additional template letters from CHA and the American Hospital Association, to support hospitals’ opposition to CMS’ unlawful proposals.

In the letter, CHA urges CMS to:

  • Withdraw its unlawful price transparency proposals, as CHA strongly believes they will only confuse beneficiaries.
  • Immediately abandon its policy to fully implement and expand site-neutral payment policies for clinic visits in excepted and non-excepted off campus provider-based hospital outpatient departments as required by a recent court decision, and refund payments withheld in CY 2019.
  • Halt the use of inpatient prospective payment system (IPPS) hospital area wage index policies finalized in August for federal fiscal year 2020 IPPS payments in the CY 2020 OPPS system. CHA continues to believe CMS’ policy of “robbing Peter to pay Paul” is not only unlawful but a dangerous precedent in area wage index policy that must be reversed.
  • Move forward with full retroactive adjustments that are not budget neutral for 340B hospitals.

It is critically important that members share with regulators the important work already underway in your organization to provide patients with estimates of their out-of-pocket costs, and how these payment policies will negatively impact your patients and communities. To assist in this effort, CHA has prepared a CEO letter template that members can use to support opposition to several issues outlined in CHA’s comment letter.

The American Hospital Association has also made available two issue-specific model comment letters on price transparency and 340B. All letters are customizable, and only one letter is necessary for submission. Member input is extremely important, as these proposals inappropriately and unnecessarily harm California’s hospitals.

Comments are due by 2 p.m. (PT) on Sept. 27. It is vital that members submit their letters electronically in PDF format at by 2 p.m. (PT) on Sept. 27. If you submit comments to CMS, please share them with Nicole Hoffman at