- In comments to the CMS released this week, hospital organizations fervently opposed the agency’s proposals to cut hospital 340B drug payments and reduce reimbursement for off-campus hospital outpatient departments.
- The American Hospital Association (AHA) comments suggested CMS suspend the star ratings program and electronic clinical quality measure reporting requirements as well as cancel Stage 3 of the Meaningful Use program.
- Industry groups did support the CMS proposal to push back implementation of appropriate use criteria (AUC) for advanced diagnostic imaging, but urged for a longer delay
The CMS is seeking comments on its proposed changes to the Physician Fee Schedule and the hospital outpatient prospective payment system (HOPPS). In their comments, industry groups pushed for some delays to reconsider data being used to set payment rates, and asked for more stringent attempts to reduce regulatory burden on providers.
Hospitals reserved their strongest language for the proposed 340B changes and the proposal to cut payments for outpatient procedures at off-campus departments. CMS is planning a major cut to payments under the 340B program, which requires drug companies to supply outpatient drugs to certain providers at reduced costs. AHA said rising drug costs should be addressed by pharmaceutical companies, and that savings from the payment cuts would not be seen by beneficiaries.
AHA said the outpatient procedure payment change is arbitrary and capricious, has a questionable legal and policy basis and threatens access to care. The proposed rule would set the payments at 25% of the regular rate instead of 50% as it is now. AHA and the Federation of American Hospitals actually suggested CMS increase the current rate.
That is likely to be an uphill battle for hospitals. Commercial payers have joined the CMS in asking for more site neutral payments as they look to reduce costs by steering patients toward outpatient settings. Hospitals that see this movement and are making their own investments in outpatient services, however, don’t want to be hamstrung.
AHA also highlighted its concerns that CMS is collecting inaccurate and incomplete data for new clinical lab fee schedule payments rates, and said that will result in rates that “do not accurately reflect the broad spectrum of private payer payment rates as Congress intended.”
Organizations representing physician groups asked for more clarifications on eligibility for some CMS value-based care initiatives, and were also supportive of delaying appropriate use criteria requirements to ensure providers understood the new regulations and were not too restricted by them.
One clear area of agreement was support for expanding the list of approved Medicare telehealth services. AMGA said research shows telehealth can provider easier access to beneficiaries without sacrificing care quality. “Numerous studies have, again, shown telehealth to be substitutable, cost effective, quality improving, and preferred by beneficiaries,” the group wrote. “We again urge CMS to substantially re-evaluate its telehealth and (remote patient monitoring) payment policies particularly related to Alternative Payment Models.”
The industry is moving forward with telehealth initiatives, albeit slowly. Providers are urging the government to hop on the bandwagon and work with health systems to set regulations as they consider technology investments. Meanwhile, they are looking to reduce reporting requirements that burden providers or don't promote improved care quality.