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.

However, these roles are not explicitly funded; instead, they are built into the overall hospital cost structure and supported by revenues received from providing direct patient care. Hospitals are also subject to more comprehensive licensing, accreditation and regulatory requirements than other settings.

Yet some policymakers want to make total payment for a service provided in a hospital the same as when a service is provided in a physician office or ambulatory surgery center.

Section 603 of the Bipartisan Budget Act of 2015 enacted site-neutral payments for new, off-campus provider-based hospital outpatient departments, despite different cost structures between HOPDs and physician offices. Subsequently, with AHA’s support, the 21st Century Cures Act established exceptions for certain off-campus HOPDs that were under construction at the time BiBA was passed in November 2015. Some, including the Medicare Payment Advisory Commission, have advocated for even greater use of such “site-neutral” payments.

The AHA continues to urge Congress to reject calls for any additional site-neutral payment policies for HOPDs. We also urge CMS to implement its policies for 2018 and beyond in the most flexible manner possible.

Related Resources

n an effort to ensure correct payment for services furnished in off-campus provider-based departments of hospitals, the Centers for Medicare…
AHA letter to Representative Kilmer expressing support of H.R. 2552, the “Protecting Local Access to Care for Everyone Act.” 
Legal Documents
Introduction Plaintiffs’ opening brief explained the clear limits that Congress imposed on the ability of the Centers for Medicare & Medi
This study examines how Medicare Fee-for-Service (FFS) beneficiaries receiving surgical care in HOPDs compare to those receiving care in ASCs.
Legal Documents
MINUTE ORDER resetting the briefing schedule after consideration of the parties' response to the Court's February 27, 2019 Minute Order.
Legal Documents
The parties to the above-referenced related actions respectfully submit this response to this Court’s minute order of February 27, 2019, which directed the…