On September 11, United States of Care (USofCare) submitted a comment letter in response to a proposed rule by the Center for Medicare & Medicaid Services (CMS). Pulling insights from our listening work across the country, we commend CMS for the provisions in this rule that will help advance health equity by increasing hospital pricing transparency and affordability while also urging the agency to consider site-neutral payment policies.
This proposed rule, entitled “Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs; Payment for Intensive Outpatient Services in Rural Health Clinics, Federally Qualified Health Centers, and Opioid Treatment Programs; Hospital Price Transparency; Changes to Community Mental Health Centers Conditions of Participation, Proposed Changes to the Inpatient Prospective Payment System Medicare Code Editor; Rural Emergency Hospital Conditions of Participation Technical Correction,” contains key provisions that will increase hospital pricing transparency by making hospital standard charges data more accessible and consistent and strengthen enforcement of hospital transparency requirements to ensure compliance.
The proposed rule also includes an expansion of Intensive Outpatient Program (IOP) and Partial Hospitalization Program (PHP) programs at Hospital Outpatient Departments (HOPDs)– a positive step forward, but a goal that won’t be fully realized until site-neutral payment reform is established in HOPDs.
USofCare is appreciative of the opportunity to comment on this proposed rule.