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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documentation burden, CHA urges the agency to withdraw its payment proposal and engage stakeholders to address the outdated coding system and improve payment accuracy in the future.
