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FAH Comments on 2019 OPPS Proposed Rule

FAH Comments on 2019 OPPS Proposed Rule

This afternoon FAH filed comments with CMS regarding the 2019 Hospital Outpatient Prospective Payment System (OPPS) proposed rule.

Key policy recommendations in the letter include:

Proposal and Comment Solicitation on Method to Control Unnecessary Increases in the Volume of Outpatient Services

FAH strongly opposes a proposed adjustment to the payment rate for clinic services “because it is not a method for controlling unnecessary increases in volume, it addresses a purported volume increase that Congress has already addressed under section 603 of the Bipartisan Budget Act of 2015 (“Section 603”), it fails to provide any deference to physician’s judgment as to the clinical necessity of the hospital outpatient setting, and the payment reduction may have unintended and counterproductive effects, including volume increases and decreased beneficiary access.”

Expansion of Clinical Families of Services at Excepted Off-Campus Departments of a Provider

FAH wrote that we “strongly oppose CMS’s renewed proposal to restrict the expansion of clinical families of services at excepted PBDs (off-site departments), reiterating our prior objections to the proposal and noting the absence of any information indicating that this burdensome policy is now warranted or appropriate.”

Also reiterating concerns that limiting the types of services furnished by excepted PBDs and reimbursable under OPPS would run contrary to Congress’ direction, is unworkable, and would be administratively burdensome.

Proposed Adjustment for Rural Sole Community Hospitals and Essential Access Community Hospitals

“FAH supports CMS’s proposal to provide this important payment adjustment. These hospitals are typically the chief, if not sole, source of community outpatient care for rural residents and this adjustment is vital to ensuring continued access to the care they need.”

Proposed OPPS Payment for Drugs Acquired Through the 340B Program

FAH reiterated our support for CMS’s proposed 340B payment policy and agrees that it is an appropriate action by the Secretary.

Requirements for the Hospital Outpatient Quality Reporting (OQR) Program

“FAH commends CMS for its proposed application of the Meaningful Measures initiative to the hospital outpatient quality reporting program. Prioritizing and reducing the number of quality measures addresses our previously expressed concerns about the burden of managing many measures. FAH supports a focus on measures designed specifically for improving patient care and working towards meaningful patient outcomes.”

Proposed Additional Hospital Inpatient Quality Reporting (IQR) Program Policies

FAH supports CMS’s proposal to remove three “Communication About Pain” questions from the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) measures, but urged the agency to find another way to measure a patient’s pain level.

FAH also expressed a desire to overhaul the entire HCAHPS system, writing, “it is vitally important that CMS take this opportunity to develop an updated HCAHPS system rather than to continually edit the existing one. The data on which the HCAHPS survey was built is now dated and the patient experience and healthcare landscapes have vastly changed. Consideration of the opioid epidemic is only one of the necessary changes. It is time for CMS to re-evaluate all the domains and questions currently in the HCAHPS.”

Requests for Information

FAH also responded to CMS’s Requests for Information on Promoting Interoperability and Electronic Health Care Information, Price Transparency, and Leveraging Authority for the Competitive Acquisition Program for Part B Drugs and Biologicals for a Potential CMS Innovation Center Model. Comments on each of these proposals reiterated points FAH has made in the past on these topics.

Click here to find the complete letter.