Executive Vice President
American Hospital Association
July 19, 2021
Today’s rule includes a number of proposals that will help hospitals and health systems better provide care in their communities. We are pleased that CMS recognizes the unique role that hospital outpatient departments serve in caring for patients, and that it proposes to roll back two problematic policies it advanced last year. The first policy would have eliminated the list of medically complex services that Medicare will only pay for when performed in the inpatient setting, and the second would have allowed very complicated procedures to be provided in ASCs, both of which could have negatively impact Medicare patients’ safety and quality of care. Hospital outpatient departments are held to higher regulatory standards and are often the best setting for patients with the most severe chronic conditions.
We also welcome the request for information on the Rural Emergency Hospital model, which will help rural hospitals continue to serve as an access point to care in their communities. The pandemic has been especially challenging to rural facilities and this model will help to ensure that patients continue to have the access they need.
Finally, hospitals and health systems are committed to helping patients access the information they need to make decisions about their care, including financial information. We will closely review the agency’s regulations related to price transparency and advocate that any final policies meet this objective. However, we are deeply concerned about the proposed increase in penalties for non-compliance, particularly in light of substantial uncertainty in the interpretation of the rules.
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