Premier Statement on the CY 2019 OPPS Final Rule

By Blair Childs, senior vice president of public affairs, Premier

The administration’s decision to pay physician fee schedule rates, instead of outpatient rates, for all outpatient clinic visits is misguided for two reasons. First, CMS lacks the statutory authority to implement this policy for facilities that Congress clearly exempted. Second, while we’re pleased that CMS did not expand this policy to new lines of services in off-campus provider-based departments, we continue to maintain that CMS’ ‘site-neutral’ payment policies overall do not recognize the overhead cost differences between physician practices and provider-based outpatient clinics.

At a time when providers are focusing on total cost of care and two-sided risk, this policy applies micro-managing cuts that foreclose health system decision-making based on how to best deliver care to patients. In fact, 139 House members and 48 Senators raised these concerns, calling on the agency to reconsider its proposal that they say flies in the face of congressional intent and could jeopardize access to our nation’s seniors.

Premier is also concerned about the roughly 29 percent payment cut for 340B drugs to non-excepted off-campus departments of hospitals that are paid under the physician fee schedule.

Instead of expansive payment adjustments, CMS should focus on methods to encourage providers to adopt risk-based alternative payment models, which are driving sustainable savings for the Medicare program.