WHA Submits Comment Letter on 2019 Outpatient Payment Rule

Concerns over site-neutral payments; urges fixes to Bay State Boondoggle

October 02, 2018

WHA urged the Centers for Medicare & Medicaid Services (CMS) to abandon its proposal to cut outpatient payments for hospital outpatient departments, and to do all within its power to fix the Bay State Boondoggle’s impact for hospital outpatient payments in comments on the 2019 Outpatient Prospective Payment System (OPPS) rule. WHA also thanked CMS for its efforts to reduce duplicative and unnecessary quality reporting measures in the hospital outpatient and ambulatory surgery center settings.

In the comment letter, WHA took issue with CMS’ proposal to reduce payments to off-campus hospital outpatient departments by $760 million annually via a reduction in reimbursements for clinic visits and new lines of services at all off-campus hospital outpatient departments. (Read more about this newest proposed site-neutral payment policy and WHA’s efforts to push back on it in the article on page 1.)

WHA also requested CMS to use its authority to fix the adverse impacts the Bay State Boondoggle continue to have on hospital outpatient payments under the Area Wage Index. While the Area Wage Index is supposed to adjust payments based on local market conditions, the Bay State Boondoggle was a provision thrown into the Affordable Care Act which manipulated payments to unfairly benefit states on the east and west coasts at the expense of other states, like Wisconsin. In the comment letter, WHA asked CMS to use its authority to decouple the OPPS wage index from Inpatient Prospective Payment System (IPPS) rule in a manner that restores accuracy and fairness to the calculation. 

CMS’ proposed rule also included several reforms to quality measures under hospital outpatient and ambulatory surgical center (ASC) reporting rules. WHA thanked CMS for its continued effort to reduce unnecessary burdens on hospitals while focusing on the appropriateness of measures in the various pay-for-performance programs and offered support of these efforts. Read more about these and other proposals in WHA’s full comment letter, or contact WHA’s Director of Federal and State Relations Jon Hoelter, or WHA’s Chief Quality Officer Beth Dibbert for more information.

This story originally appeared in the October 02, 2018 edition of WHA Newsletter