The Centers for Medicare & Medicaid Services should delay implementing the site-neutral provisions of the Bipartisan Budget Act of 2015 until it can provide fair and equitable payment to hospitals for nonexcepted services, AHA told the agency today, commenting on the hospital outpatient prospective payment system proposed rule for calendar year 2017. “The hospital field and more than half of the U.S. House and Senate this spring urged CMS to provide reasonable flexibility when implementing the BiBA site-neutral provisions in order to ensure that Medicare patients have continued access to the highest quality hospital outpatient care in their communities,” wrote AHA Executive Vice President Tom Nickels. “Instead, CMS has proposed a short-sighted and unworkable set of policies that provide no reimbursement directly to hospitals in CY 2017 for the services they provide to Medicare beneficiaries.” Among other changes to the proposed rule, AHA recommends that CMS allow excepted hospital outpatient departments to relocate and rebuild without triggering payment cuts; protect hospitals’ ability to offer expanded lines of service without a loss of reimbursement; and allow hospitals to transfer ownership of individual HOPDs and maintain their excepted status.