The AHA yesterday asked the Medicare Payment Advisory Commission to consider certain issues before making draft recommendations related to provider consolidation and stand-alone emergency departments. MedPAC last month discussed, in the context of vertical integration, whether it should advance new and/or past recommendations on site-neutral payment. “The AHA strongly opposes these site-neutral options,” AHA Executive Vice President Tom Nickels said in a letter to the commission. “We believe it is premature and potentially disruptive to providers, patients and communities to recommend or implement additional site-neutral policies while providers are currently in the midst of implementing the site-neutral policies contained in the Bipartisan Budget Act of 2015.” AHA also “strongly opposes revocation of the ED exemption in BiBA,” a policy option discussed by MedPAC last month in relation to hospital-based off-campus emergency departments and independent freestanding emergency centers. Among other comments, AHA expressed concern that “considering provider-based OCEDs in the same category as IFECs is misleading and inappropriate given the important differences between the two."