Site-Neutral Payment Proposals Letters

RE: CMS–1832–P Medicare and Medicaid Programs; Calendar Year 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program

Hospitals and health systems are experiencing significant financial pressures that challenge their ability to provide 24/7 care for the patients and communities they serve. As Congress begins to focus on its end-of-the-year work, America’s hospitals and health systems respectfully request that you consider the following priorities.

AHA letter urging Congress to act on key priorities in Lame-duck session.

AHA comments regarding the ongoing government funding discussion, AHA Urges Congress to eliminate Medicaid DSH cuts, reject Site-neutral payments.

The American Hospital Association and American Society of Health-System Pharmacists express concerns that proposed site-neutral legislation in the House and Senate could reduce access to patient care and jeopardize patient safety.

AMERICA’S HOSPITALS AND HEALTH SYSTEMS   May 23, 2023

In a letter to the Centers for Medicare & Medicaid Services, AHA expresses continued concerns about audit determinations denying hospitals a “mid-build exception” to the site-neutral payment policy and urged the agency to extend by at least 180 days the July 18 and Sept. 16 deadlines for hospitals to identify and return, respectively, any overpayments.

The AHA appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ hospital outpatient prospective payment system and ambulatory surgical center payment system proposed rule for calendar year 2020.

AHA letter to Representative Kilmer expressing support of H.R. 2552, the “Protecting Local Access to Care for Everyone Act.” 

The AHA is deeply disappointed in certain proposals that CMS has chosen to set forth in this proposed rule for the CY 2019 outpatient prospective payment system (OPPS), which run afoul of the law and rely on the most cursory of analyses and policy rationales. Taken together, they would have a chilling effect on beneficiary access to care and new technologies, while also dramatically increasing regulatory burden.

The AHA supports several of the proposed rule’s provisions. In particular, we appreciate and endorse the agency’s proposal to permanently withdraw the 25% Rule; however, we have substantial concerns with the associated budget neutrality adjustment proposed by CMS. We also support the proposed changes related to co-located facilities, and the streamlining of the LTCH quality reporting program. In addition, this letter reiterates our concerns related to underpayment for site-neutral cases.

Medicare pays long-term care hospitals less than half the cost of care for site-neutral cases under the LTCH prospective payment system, AHA told CMS.

As you know, the Centers for Medicare & Medicaid Services (CMS) published on July 6 its calendar year 2017 outpatient prospective payment system (OPPS) proposed rule for implementing Section 60

Senate singed HOPD letter

These are model comments to guide you in crafting your own letter to the Centers for Medicare & Medicaid Services on its proposed rule for the calendar year 2017 outpatient prospective payment

AHA recommendations regarding CMS' upcoming rulemaking for Section 603 of the Bipartisan Budget Act of 2015.

The AHA supports the cautious exploration of a site-neutral payment policy that applies exclusively to patients who are clinically similar and can safely be treated in either setting.