fah hospital policy blog

Perspectives on health policy affecting America’s hospitals and the patients we serve.

FAH Comments on 2018 Proposed OPPS and PFS Rules

September 11, 2017 | FAH Policy Blog Team

Category: Financing, Medicare

Today, the Federation of American Hospitals (FAH) filed comment letters in response to CMS’s proposed rules governing Medicare hospital outpatient payments and physician fee schedule payments in 2018.

Some of the issues addressed by FAH in the letters include:

340B Drug Discount Program

The letter states that if CMS finalizes its proposed payment reduction for separately payable drugs acquired under the 340B program, it must “implement this payment reduction in a budget neutral manner within OPPS.”

Total knee replacement

FAH strongly recommends that the total knee replacement procedures remain on the CMS Inpatient only (IPO) list. The letter notes that these procedures place patients at risk for several complications including but not limited to deep vein thrombosis, pulmonary embolism and infections among other issues. This is especially true for a Medicare population that is more elderly and typically more frail than a commercial population.

Outpatient payment for new hospital off-campus provider based departments (PBD)

FAH strongly opposes CMS’s proposal to reduce payment from the current 50% of the outpatient rate to 25%. Instead, the FAH letter recommends a rate of 60% and presents empirical data and analysis supporting its position.

Direct supervision enforcement in rural hospitals

While the FAH letter acknowledges and appreciates CMS’s proposal for a two year enforcement moratorium, we urge CMS to extend it permanently.

You can read the entire OPPS letter here and find the PFS letter here.