AAMC Comments on the Proposed Rule for the 2022 Outpatient Prospective Payment System
The AAMC submitted comments on September 15 regarding the proposed rule for the 2022 Calendar Year Outpatient Prospective Payment System (OPPS) from the Centers for Medicare & Medicaid Services (CMS). In addition to its comments on hospital payment and quality provisions, the AAMC letter also addresses updates to the Mandatory Radiation Oncology Model. [refer to related story].
Below are highlights of AAMC’s comments on the hospital payment and quality provisions in the proposed rule:
- 340B Drug Pricing Program: The CMS proposed to continue paying for separately payable drugs reimbursed under the OPPS and acquired through the 340B program at the average retail price less 22.5%. The AAMC urged CMS not to continue reimbursement reductions for drugs acquired 340B and requested that the agency provide more transparency in how it calculates and implements the budget neutrality adjustment.
- Data sources for pricing: The CMS proposed to use the data sources of the year 2019, or the year 2018, if applicable, for the OPPS pricing of the year 2022. The AAMC supported the use of CY data 2019 as a better overall approximation of the expected CY 2022 hospital outpatient services.
- List of hospitalized patients only (IPO): The CMS proposed to stop the elimination from the IPO list and return all 298 services that were deleted in the final OPPS CY 2021 rule to the IPO list, starting in CY 2022. The AAMC urged CMS to finalize its proposal to stop elimination from the list of IPOs and suggested that CMS work with stakeholders as part of an ongoing assessment process to determine what procedures and treatments have been found to be carried out safely and successfully in outpatient consultations.
- To place-Neutral payment policy: The CMS proposed to continue the payment reductions for clinic visits (Healthcare Common Procedure Coding System [HCPCS] code G0463) when provided in excluded departments based on off-campus vendors in CY 2022 and beyond. The AAMC has urged CMS not to continue with its neutral payment cuts for the site into 2022 and beyond.
- Transparency of hospital prices: The CMS proposed to increase civil monetary penalties (CMP) for non-compliance of hospitals based on the number of beds in a hospital, as documented on the hospital’s cost report. The AAMC urged CMS not to finalize new CMPs for hospitals deemed not to comply with price transparency requirements.
- Health insurance wage index: The CMS has proposed to continue its policy of increasing the salary indices of low-wage hospitals. The AAMC supported the agency’s pursuit of the low wage index policy for the OPPS wage index of CY 2022 and also urged CMS to extend the transitional 5% cap in CY 2022 to all hospitals given the unique impact the COVID-19 public health emergency continues to have. have on the finances of the hospital and the salaries of the area.
- List of procedures covered by outpatient surgery centers (ASC-CPL): CMS proposed to restore the general standards and exclusion criteria in place before the year 2021 for the addition of procedures to ASC-CPL, to remove 258 of the 267 procedures added to the list in 2021 and to establish an appointment process to add procedures to the list. The AAMC supported the finalization of the agency’s proposed appointment process, as well as the re-establishment of general standards and exclusion criteria, which provide essential protections for patient safety.
- Payment for COVID-19 sample collection: CMS asked for comments on whether the payment for the collection of COVID-19 samples under the OPPS (HCPCS code C9803) should be made permanent. The AAMC has strongly supported the ongoing payment of COVID-19 sample collection under the OPPS to facilitate testing for COVID-19.
- Direct supervision through interactive communications technology: The CMS requested comments on the advisability of permitting permanent direct supervision of certain rehabilitation services using two-way audio / video communication technology. The AAMC has supported the continuing authorization of hospitals to respond to direct supervision through interactive telecommunications technology for certain rehabilitation services, which allows hospitals to safely and flexibly provide selected rehabilitation services.
- Mental health services provided remotely by hospital staff: The CMS asked for comments on the extent to which hospitals have charged for mental health services provided to beneficiaries in their homes through communication technologies during the public health emergency – and whether hospitals anticipate continued demand for this model. care after its conclusion. The AAMC has supported the sustainability of these flexibilities allowing hospital staff to remotely provide mental health services provided to beneficiaries at home.
- Adoption of new measures and modification of existing measures for the Outpatient Quality Reporting (OQR) program: The CMS proposed to adopt three new quality measures and to modify two existing measures based on patient surveys in the OQR program. Regarding the COVID-19 vaccination measure among healthcare workers, the AAMC believes that CMS should address the outstanding issues that have a direct impact on the design and feasibility of the measure before it is included in the measure. the program. The AAMC supported the measurement of outpatient patient experience and encouraged CMS to monitor response rates regarding new online survey modes proposed for outpatient assessment of providers and healthcare systems. health (CAHPS).
- Potential efforts to address health equity in the OQR hospital program: CMS asked for comments on how it could address health disparities through its quality reporting programs. The AAMC suggested that CMS work with stakeholders to improve data collection to better measure and analyze disparities in a way that builds an evidence-based, valid and reliable framework towards supplier accountability for the equity in health. The AAMC responded that CMS should pursue a policy supporting the collection of standardized information on multisectoral risks that will help improve risk stratification and adjustment beyond demographic data elements at the individual level. Data collection and systems for capturing unmet social needs at individual and community levels should be used together to better identify disparities in quality and equity to guide improvement interventions. The AAMC reiterated previous comments in response to the proposed FY2022 rule for the potential inpatient system. [refer to related story] that the agency should encourage the reporting and use of actionable data on social health needs instead of using statistically imputed estimates of race and ethnicity to stratify reporting, in part because race and ethnicity in themselves are not risk factors and that reliance on unchanging characteristics alone is not informative for the intervention.
- Advancing digital quality measurement: The CMS has requested comments to inform the development of future rules on the agency’s goal of moving to digital quality measurement in its quality and performance reporting programs by 2025. The AAMC has suggested that the CMS refine its definition of digital quality metrics to focus first on currently available metrics. valid and reliable digital data sources, set clear and specific parameters for what the agency hopes to achieve, and spell out what it expects from hospitals as it aims to move to digital quality measurement by 2025 .