Premier Comments on CY 2024 Medicare Outpatient Proposed Rule

Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2024 Outpatient Prospective Payment System (OPPS) proposed rule. In its comments, Premier urges CMS to:

• Adopt new or supplemental data sources to ensure labor costs are adequately reflected in the Medicare hospital payment update;
• Issue a formal Request for Information (RFI) to proactively engage stakeholders on incorporating incentives and appropriate reimbursement models for artificial intelligent (AI) technology into Medicare payment systems;
• Finalize its proposal to leverage the new Medicare intensive outpatient benefit to increase access to treatment services for opioid use disorders;
• Partner with the Departments of Labor and Treasury to better align the various current price transparency requirements—with a focus on implementation of the Transparency in Coverage requirements—to minimize confusing or conflicting information for patients;
• Consider alternative non-budget neutral policy solutions to address drug shortages within its authority such as paying a differential reimbursement for domestically manufactured essential medications;
• Not finalize adoption of the Hospital Outpatient Volume Data on Selected Outpatient Procedures measure – and instead work with stakeholders to identify measures that more appropriately evaluates the procedure shifts in inpatient to outpatient settings and related quality of care; and
• Continue to evaluate and revisit the COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) measure and its utility for patients and facilities as part of next year’s rulemaking. At a minimum, Premier urges CMS to revise the measure to only require annual reporting.