Under a so-called “site-neutral” payment policy, the payment for a service provided to a patient is the same regardless of the setting where the service is provided.
FAH and its member hospitals agree with the goal of ensuring patients receive the right care, at the right time, in the right setting. However, blunt site-neutral payment policies, such as the current reduction for clinic services performed in hospital provider-based departments ignore fundamental functional and cost structure differences between hospitals and physician offices, among other settings, and the unique, mission-critical services communities rely on hospitals to provide.
For example, hospitals provide 24/7 access to emergency care and disaster relief, serve as safety net providers in their communities, and treat more medically complex patients who are more often chronically ill, disabled, and indigent. In addition, regulatory requirements such as EMTALA, hospital Conditions of Participation, hospital state licensure, and complex cost reports impose substantial resource and cost burdens that physician offices and ambulatory surgery centers do not have, and therefore are not reflected in their payments.