Site-Neutral Payment
Americans rely heavily on hospitals to provide 24/7 access to care for all types of patients, to serve as a safety net provider for vulnerable populations, and to have the resources needed to respond to disasters. Hospitals and their outpatient departments provide access to critical services that are not otherwise always available in the community, treat patients with more severe conditions than other sites of care, and are subject to more comprehensive licensing, accreditation, and regulatory requirements than other settings.
However, these roles and differences are not explicitly funded; instead, they are built into the overall hospital cost structure and supported by revenues received from providing direct patient care.
Yet some policymakers want to enact additional site-neutral payment cuts that would make total payment for a service provided in a hospital setting the same as when a service is provided in a physician office or ambulatory surgery center.
Payment proposals that attempt to treat hospital outpatient departments the same as these other ambulatory sites of care ignore this very different level of care provided by hospitals and the needs of the patients and communities cared for in that setting. Hospitals need to continue to provide emergency stand-by capacity, are open 24/7 to all who seek care regardless of ability to pay and have myriad regulatory requirements imposed on them – all adding to the overall cost of care.
AHA Position:
Congress should oppose additional site-neutral payment cuts, which would reduce access to critical health care services, especially in rural and other underserved communities.
Key Resources
- Letter: AHA Details Legislative Priorities for Congressional Leaders
- Study: Comparison of Care in Hospital Outpatient Departments and Independent Physician Offices
- Study: Comparison of Care in Hospital Outpatient Departments and Independent Physician Offices Among Cancer Patients
- Letter: AHA Comments on CMS CY 2026 Outpatient, ASC Proposed Payment Rule
- Action Alert: TAKE ACTION: Engage Lawmakers in August to Build Support for Key Priorities
- Fact Sheet: Estimated Impact of Hospital On-campus and Off-campus Site-Neutral Proposal
- Fact Sheet: Medicare Site-neutral Legislative Proposals Under Consideration Would Jeopardize Access to Care for Patients and Communities
- Fact Sheet: Medicare Hospital Outpatient Site-Neutral Payment Policies
- Fact Sheet: Hospital Outpatient Department Billing Requirements
- Myth vs Fact: Site-neutral Payment Policies Infographic
- Fact Sheet: Facility Fees
- Analysis: Hospitals and Health Systems Are Critical to Preserving Access to Care for Rural Communities
- Infographic: Medicare Significantly Underpays Hospitals for Cost of Patient Care
- Chart: Reject Site-Neutral Payment for Lower Standards of Infusion Care
- Infographic: Site-neutral Payment Policies Threaten Access to Hospital-level Care
- Proposals to Reduce Medicare Payments Would Jeopardize Access to Essential Care and Services for Patients
- Infographic: Setting the Record Straight: Private Equity and Health Insurers Acquire More Physicians than Hospitals
- Study: Comparison of Medicare Beneficiary Characteristics Between Hospital Outpatient Departments and Other Ambulatory Care Settings (KNG Health Consulting LLC, on behalf of the AHA)