AHA Comments on CMS’s Outpatient PPS and ASC Proposed Rule for CY 2020

The AHA appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ hospital outpatient prospective payment system and ambulatory surgical center payment system proposed rule for calendar year 2020.

We urge CMS to abandon its proposals that would:

• Mandate disclosure of negotiated charges between health plans and hospitals;
• Continue “unlawful” payment cuts for 340B drugs and excepted hospital outpatient clinic visits; and
• Require prior authorization for certain outpatient department services.

In addition, the AHA opposes proposals to remove total hip arthroplasty from the inpatient-only list, and add total knee arthroplasty and several coronary intervention procedures to the list of ASC-covered procedures. We also voiced strong support for a proposal to change the minimum required level of supervision from direct supervision to general supervision for hospital outpatient therapeutic services provided by all hospitals and critical access hospitals.