Comment Letter to CMS on CY 2016 Hospital OPPS Proposed Rule
August 28, 2015
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244-1850
RE: CMS-1633-P, Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Short Inpatient Hospital Stays; Transition for Certain Medicare-Dependent, Small Rural Hospitals under the Hospital Inpatient Prospective Payment System (Vol. 80, No.130), July 8, 2015
Dear Mr. Slavitt:
On behalf of The Hospital & 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) 2016.
HAP supports many of the payment and policy proposals contained within the proposed rule and looks forward to working with CMS to continue to promote payment accuracy and drive quality improvement.
In particular, we believe the proposed changes to the two-midnight policy represent a positive step in addressing issues created by the policy.
Key areas of concern include the continued imposition of the 0.2 percent reduction implemented with the two-midnight policy, and the application of a 2 percentage point reduction to the OPPS conversation factor to correct for the Office of the Actuary’s previous overestimation of the amount of packaged laboratory payments in the OPPS for laboratory tests.
We also ask CMS to provide separate payment under the OPPS for advance care planning, and adjust the proposed comprehensive observation service ambulatory payment classification.
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 Laura Stevens Kent, vice president, federal advocacy, at (202) 863-9287, or Kate Slatt, senior director, health care finance policy, at (717) 561-5317.
Jeffrey W. Bechtel
Sr. Vice President
Health Economics and Policy