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The AHA Wednesday expressed “extreme dismay” with the provisions for new off-campus hospital outpatient departments contained in the Centers for Medicare & Medicaid Services’ (CMS) outpatient prospective payment system (PPS) proposed  for 2017. 

“It appears that CMS is aiming to freeze the progress of hospital-based health care in its tracks,” AHA Executive Vice President Tom Nickels said of the regulations for new off-campus provider-based departments, or PBDs, contained in the agency’s July 6 proposed rule.

The rule proposes to implement the site-neutral provisions of Section 603 of the 2015 Bipartisan Budget Act. With the exception of dedicated emergency department services, the section requires services furnished in off-campus PBDs that began billing under outpatient PPS on or after Nov. 2, 2015 to no longer be paid under that outpatient payment system.

Instead these services would be paid under other applicable Part B payment systems beginning Jan. 1, 2017. CMS proposes that, in 2017, the physician fee schedule would be the applicable payment system for the site-neutral rates for the majority of services furnished in a new off-campus PBDs.

CMS would pay physicians furnishing services in these departments at the higher “nonfacility” PFS rate. There would be no payment made directly to the hospital by Medicare. Existing off-campus PBDs that expand their services to include those in new clinical families would receive the site-neutral rate for those services.

In addition, any existing off-campus PBD that relocates after Nov. 2 would lose its excepted status and be subject to site-neutral payments. An existing off-campus PBD that undergoes a change of ownership would only maintain its excepted status if the new owner accepts the existing Medicare provider agreement from the prior owner.

“We are extremely dismayed by the short-sighted policies” in the proposed rule, Nickels said. He said the AHA will submit detailed comments to the agency urging it to revise “these misguided policies so that hospitals can continue to provide the highest quality health care to their communities.”

PPS update. In the rule, CMS proposed to update outpatient PPS rates by 1.55% in 2017 compared to 2016.

Meaningful use. As urged by the AHA, CMS proposes to offer greater flexibility in the meaningful use of electronic health records under the Medicare program by shortening the reporting period for 2016 from a full year to 90 days for all hospitals and physicians. CMS also proposes, beginning in 2017, to remove two measures for eligible hospitals and critical access hospitals – computerized provider order entry and clinical decision support – and reduce the requirements for patients to view, download and transmit their information from 5% to at least one patient.

Stage 3 of meaningful use would still be required by all hospitals in 2018. However, the thresholds for most measures would be reduced to the level required in Modified Stage 2.

Quality reporting. For the CY 2020 outpatient quality reporting program, CMS proposes seven new measures – hospital admissions and ED visits for outpatient chemotherapy patients, hospital visits following outpatient surgery, and five measures derived from a new Outpatient and Ambulatory Surgical Center Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) survey.

The OAS CAHPS is a 37-item survey intended to assess the experience of care for patients that have received surgeries and other procedures in HOPDs and ASCs. CMS would require OAS CAHPS data to be collected and submitted quarterly starting with visits on Jan. 1, 2018. CMS proposes the same measures from the OAS CAHPS for the CY 2020 ASC Quality Reporting Program.

Comments on the proposed rule are due Sept. 6.