WHA was on capitol hill last week urging Wisconsin’s Congressional Delegation to sign onto a letter WHA is spearheading that asks CMS to withdraw a provision in its proposed 2019 Outpatient Prospective Payment System (OPPS) rule. The rule would institute so called “site-neutral” payments for clinic visits at off-campus hospital outpatient departments and is anticipated to reduce payments by about $30 million for about 40 Wisconsin hospitals in 2019. The impact could be as much as $440 million in cuts over the next 10 years. A HEAT alert has also gone out to WHA HEAT members, asking members of impacted hospitals to contact their legislators and urge them to sign onto this letter.
What is particularly concerning about the proposed rule is that it seems to fly in the face of two separate acts of Congress that previously grandfathered hospital outpatient departments and seemingly protected them from such payment cuts. The 2015 Bipartisan Budget Act and the subsequent 21st Century Cures Act instituted a new payment structure for future off campus hospital outpatient departments, but specifically grandfathered those previously in existence as well as those already in the mid-build stage. In both cases, Congress recognized that hospitals had budgeted for their future operations based on the understanding of the existing payment rules, and that changing the rules mid-game would be unfair.
In addition to this letter coming from Wisconsin’s Congressional Delegation, WHA recently circulated a letter for impacted Wisconsin hospital and health system CEOs and leaders to sign onto, expressing their concerns over this proposal directly with CMS. This sign-on letter will be sent to CMS September 24, the deadline for official comments on the proposed rule. WHA will be back in Washington, D.C. for a fly-in with other hospital and health system leaders on September 25 to build more support for this issue. Anyone interested in participating in the fly-in, looking to sign onto the WHA member letter, or with general questions on this issue may contact WHA’s Director of Federal and State Relations, Jon Hoelter