AHA Comments on CMS Outpatient PPS /ASC Proposed Rule for CY 2019

The AHA is deeply disappointed in certain proposals that CMS has chosen to set forth in this proposed rule for the CY 2019 outpatient prospective payment system (OPPS), which run afoul of the law and rely on the most cursory of analyses and policy rationales. Taken together, they would have a chilling effect on beneficiary access to care and new technologies, while also dramatically increasing regulatory burden. Specifically, the AHA strongly opposes CMS’s proposals to:

• Reduce payment for the hospital outpatient clinic visit in excepted off-campus provider-based departments (PBDs) to the “physician fee schedule (PFS)-equivalent” rate of 40 percent of the OPPS rate (so-called "site-neutral" payments);  
   
• Reduce payment for services from expanded clinical families furnished in excepted off-campus PBDs to 40 percent of the OPPS rate; and  
   
• Continue the current policy that pays for separately payable drugs acquired through the 340B program at the rate of average sales price (ASP) minus 22.5 percent and expand this payment cut to nonexcepted PBDs.