AHA Advocacy Alliance for Coordinated Care

In 2015, Congress, as part of the debt-limit deal, included a provision that would enact site-neutral payment reductions for Medicare services that are furnished in new off-campus provider-based hospital outpatient departments (HOPDs) that are not dedicated emergency departments. The bill defines off-campus HOPDs as departments that are not on the main campus of a hospital and are located more than 250 yards from the main campus. HOPDs that were providing services by Nov. 2, 2015 will be exempt from the new payment cap and can continue billing at the HOPD rate, with the payments changes effective on Jan. 1, 2017. The AHA opposes this new payment scheme.

The AHA continues to work toward technical corrections to the law to allow off-campus provider-based HOPDs already under development to qualify as grandfathered facilities.

Lawmakers and regulators continue to consider site-neutral payment changes that would result in lower payments to hospitals. Three of these proposals include:

  • Paying hospitals for evaluation and management (E/M) services in the HOPD setting at the physician fee schedule (PFS) amount
  • Paying hospitals for 66 specified ambulatory payment classifications (APCs) at the PFS amount
  • Capping hospital payments for 12 proposed APCs at the ASC rate

The AHA strongly opposes policies to equalize Medicare payment rates for services provided in an HOPD and those performed in other clinical settings. HOPDs provide access to critical hospital-based services that are not otherwise available in the community and treat higher-severity patients for whom the HOPD is the appropriate setting. In addition, they have higher cost structures than other facilities due to the need to have emergency stand-by capacity and higher costs associated with a myriad of regulatory requirements those facilities must legally meet. The AHA Advocacy Alliance for Coordinated Care focuses on adequate payment for the higher level of care capability that hospitals provide in the outpatient setting and for post-acute care providers.  It also monitors payment reduction proposals for other care sites.




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Case Studies

Case Studies on the
Potential Impact of Cuts

Hospitals are speaking out to illustrate the potential impact the proposed E/M HOPD rate cuts may have on hospitals. View the latest case studies.


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