Comments Due Sept. 27 on 2020 Medicare OPPS Proposed Rule; MHA Draft Available

Posted on September 20, 2019

The MHA’s draft comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rule to update the Medicare fee-for-service (FFS) outpatient prospective payment system (OPPS) are available online. As proposed, the rule is estimated to increase payments to Michigan hospitals by $18 million, or 0.8%, which is significantly less than the projected 5.5% to 7% increase in healthcare inflation for 2020. The MHA’s comments focus on the CMS’ proposed changes related to the:

  • Requirements for hospitals to make available a list of their standard charges and negotiated third party payment rates.
  • Continued phase-in of payment cuts for clinic visits provided at off-campus hospital outpatient departments (HOPDs) from 70% to 40% of the OPPS rate, regardless of the facilities’ grandfathered status under Section 603 of the Bipartisan Budget Act of 2015.
  • Continuing 340B payment cuts that were implemented in 2018.
  • Revisions to the inpatient-only list.
  • Addition of procedures to the ambulatory surgery center-covered list
  • Prior authorization requirements for certain HOPD services that are often considered as cosmetic surgery, but can also be medically necessary.
  • Cost reporting, maintenance of hospital chargemasters, and related Medicare payment issues.
  • Changes to the hospital outpatient quality reporting program.

Despite recent federal court rulings in favor of hospitals (see related article), the CMS proceeded with the proposed cuts for clinic visits provided at off-campus HOPDs and the 340-B cuts. The MHA encourages hospitals to submit comments to the CMS by Sept. 27. The MHA will provide hospitals with an updated facility-specific impact analysis following release of the OPPS final rule, expected by Nov. 1 for the Jan. 1, 2020, effective date. Members with questions should contact Vickie Kunz at the MHA. 

Tags: Medicare, OPPS, 340B Drug Pricing Program, proposed rule, CMS, comments

Posted in: Member News

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