Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > OPPS-Proposed-Rule-2017-Comment-Letter


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HAP Comment Letter to CMS on the Outpatient Proposed Prospective Payment System Proposed Rule CY 2017

September 6, 2016

Andy Slavitt
Acting Administrator Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS-1656-P
P.O. Box 8013
Baltimore, MD 21244-1850

RE: CMS-1656-P, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Organ Procurement Organization Reporting and Communication; Transplant Outcome Measures and Documentation Requirements; Electronic Health Record (EHR) Incentive Programs; Payment to Certain Off-Campus Outpatient Departments of a Provider; Hospital Value-Based Purchasing (VBP) Program (Vol. 80, No.130), July 14, 2016

Dear Mr. Slavitt:

On behalf of The Hospital and Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to comment about the Centers for Medicare & Medicaid Services’ (CMS) hospital outpatient prospective payment system (OPPS) proposed rule for calendar year (CY) 2017.

This rule proposes one of the most significant payment changes in recent history related to the payment of off-campus hospital outpatient departments (HOPD). We believe the proposed implementation of the site-neutral provisions of the Bipartisan Budget Act of 2015 imposed by this rule do not properly reflect the intent of Congress and will significantly limit Pennsylvania hospitals’ and health systems’ ability to care for the populations they serve in an outpatient capacity.

HAP requests the delay of implementation of the Section 603 site-neutral policies by at least one year in order to provide appropriate time to develop fair and flexible payment policies for care provided by hospitals in outpatient settings, and properly address the operational issues facing CMS, health care providers, and ultimately, patients.

Other key areas of interest in the proposed rule include:

  • Removal of pain management questions from Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) scoring
  • Changes to meaningful use requirements in the Medicare Electronic Health Record Incentive Program

Thank you for your consideration of HAP’s comments about this proposed rule regarding outpatient payment and other provisions related to hospitals and the patients they serve in Pennsylvania.

If you have any questions, contact Kate Slatt, senior director, health care finance policy.


Jeffrey W. Bechtel
Sr. Vice President
Health Economics and Policy


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