The Centers for Medicare & Medicaid Services has a responsibility to provide fair and equitable compensation to hospitals for the care they provide to Medicare patients. Sadly, the way the agency proposes to treat new off-campus provider-based outpatient clinics falls far short of that standard. The regulations interpret a provision of last year’s Bipartisan Budget Act so narrowly as to erode a service vital to many sicker, poor, minority and elderly patients, especially in rural and inner city communities. Under the proposal, CMS would not directly provide payment to hospitals next year for services to patients provided at off-campus outpatient departments that started billing Medicare after the law was enacted. And off-campus departments that were already billing Medicare as of that date would not be compensated for new service lines they add for their communities. Nor would they be reimbursed if they relocated or expanded their facility. Sept. 6 is the deadline for comments on the proposed rule, and our model comment letter can help guide you as you craft your response. Help CMS to understand how its site-neutral policy will exacerbate your challenges in providing the best possible care to your patients and communities. Tell the agency to go back to the drawing board and come up with a fairer payment policy for 2017 or delay the regulations until it can. And make plans to join us in Washington, DC, on Sept. 13 as we take this message to Capitol Hill.    

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