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CHA Issues Summary of CY 2019 OPPS Final Rule

CHA has issued a summary of the Centers for Medicare & Medicaid Services’ final rule addressing rate updates and policy changes to the Medicare outpatient prospective payment system (OPPS) and ambulatory surgical center payment system for calendar year (CY) 2019.

David Simon

David Simon leads CHA’s Communications team in support of work to foster an environment in which hospitals and health systems can better meet their mission of care. David works closely with CHA’s advocacy, policy, and data teams to create and disseminate information to legislative leaders, regulatory bodies, the public, and CHA members.

Prior to joining CHA, David served in a communications leadership role at the Maryland Hospital Association. Before that, he spent nearly 15 years in journalism, working at newspapers in New York City and Maryland.

Ryan Witz

Ryan Witz represents members’ financial interests related to Medicare, Medi-Cal, commercial payers and other government entities. He provides support on financial and reimbursement issues affecting California hospitals and health systems, and represents CHA with stakeholders where hospital finance and technical knowledge is needed. Ryan is also involved with the development and implementation of the hospital fee and other financing programs.

FFY 2019 Uncompensated Care Payments to Come From 2014, 2015 Worksheet S-10 Data

In the federal fiscal year (FFY) 2019 inpatient prospective payment system final rule, the Centers for Medicare & Medicaid Services (CMS) finalized its second year of a three-year transition to use Worksheet S-10 data for distributing Medicare disproportionate share hospital (DSH) uncompensated care payments. CMS will use two years (FFYs 2014 and 2015) of Worksheet S-10 cost report data and one year of proxy data to distribute the uncompensated care payments for FFY 2019.

In response to comments from CHA, CMS noted in the final rule that it planned audits of the data in fall 2018. In late August, CMS began audits of selected hospitals’ FFY 2015 cost reports. A number of hospitals in California have received this data request, and must respond by Sept. 28.  

Because CMS has given the Medicare administrative contractors (MACs) only until the end of January to complete the audits, providers have a short timeline to complete this work with their MACs. Though CHA acknowledges that this presents a challenge from both technical and resource perspectives, CHA highly encourages hospitals that have received a request to respond as quickly as possible. Early communication with Noridian (or its subcontractor, Figliozzi & Company) is critical under this short timeline. A copy of the letter Noridian sent to select providers requesting documentation is attached; these letters are consistent across all MACs.

CHA Comments on CY 2019 Outpatient PPS Proposed Rule

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 provider-based departments (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