Advocacy Correspondence: CMS Comment letter, CMS-1809-P Medicare Outpatient Prospective Payment System proposed rule CY 2025

September 9, 2024

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS-1809-P
P.O. Box 8010
Baltimore, MD  21244-8010

RE:  CMS-1809-P. Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs, including the Hospital Inpatient Quality Reporting Program; Health and Safety Standards for Obstetrical Services in Hospitals and Critical Access Hospitals; Prior Authorization; Requests for Information; etc.; Proposed Rule, July 22, 2024

Dear Administrator Brooks-LaSure:

On behalf of The Hospital and Healthsystem Association of Pennsylvania (HAP), which represents approximately 235 member hospitals, we appreciate the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) Medicare Outpatient Prospective Payment System proposed rule for calendar year (CY) 2025.

HAP and its member hospitals share the American Hospital Association’s concerns regarding the payment updates proposed for outpatient hospital services for the upcoming year. Many hospitals in Pennsylvania continue to operate on negative or very thin margins. Failing to account for consistently high and rising operational costs poses significant risk to the viability of hospitals and patients’ access to care.

We were encouraged to see CMS’ consideration of the impact of the four walls requirement for Medicaid clinic services and are hopeful that if the agency’s proposal is finalized, it will result in more robust treatment options for individuals in Pennsylvania.

In addition, we incorporate, by reference, all the comments provided in the American Hospital Association’s response to the proposed rule.

Thank you for your consideration of HAP’s comments regarding this proposed rule. If you have any questions, contact me at (717) 561-5317.

Sincerely,

Kate Slatt
Vice President, Innovative Payment and Care Delivery

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Topics: Behavioral Health, Federal Advocacy, Medicare, Telehealth

Revision Date: 9/9/2024

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