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The Medicare Payment Advisory Commission should not finalize its draft recommendation to reduce payments for off-campus stand-alone emergency departments located within six miles of an on-campus hospital ED, which is not based on any analysis of Medicare beneficiaries, Medicare costs or Medicare payments and would make Medicare’s record underpayment of outpatient departments and hospitals even worse, AHA said in comments submitted Friday. Medicare margins were a record-low negative 14.8% for hospital outpatient departments and negative 9.6% for hospitals overall in 2016, with the latter expected to reach negative 11% this year, the letter notes. In other comments, AHA voiced support for a draft recommendation to allow isolated rural hospitals to convert to stand-alone EDs, and urged the commission to consider expanding the recommendation to include EDs in vulnerable urban communities as well. AHA also urged MedPAC to modify its payment adequacy calculations for long-term care hospitals to incorporate all LTCH cases. MedPAC is expected to review and vote on the ED recommendations at its April 5-6 meeting.