Comments on site-neutral payment and price transparency data in CMS’ proposed OPPS rule

The Centers for Medicare & Medicaid Services (CMS) recently issued the Calendar Year 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System proposed rule. Loren Adler and Matthew Fiedler submitted a comment letter that makes two main points about the proposed rule:

1. CMS’ imaging proposal would advance site-neutral payment, but CMS could go further. CMS’ proposal to apply site-neutral payment to imaging without contrast services furnished in excepted off-campus hospital outpatient departments (HOPDs) would reduce Medicare and beneficiary costs and weaken incentives for vertical consolidation without adversely impacting Medicare beneficiaries. Moreover, the economic logic underlying CMS’ proposal supports further expanding site-neutral payment to additional services and, likely particularly important, on-campus settings. To identify additional services suitable for site-neutral payments, CMS could use a systematic empirical framework that considers whether services are routinely delivered in lower-cost settings, the magnitude of site-of-service payment differences, and evidence that those differences are contributing to shifts toward HOPDs. Finally, CMS could more fully achieve its goal of site-neutrality by more precisely aligning its “PFS-equivalent” rates with actual Physician Fee Schedule (PFS) payment rates.
2. Adding better payer and plan identifiers to Hospital Price Transparency (HPT) data would be useful, but potentially infeasible. Improving and standardizing payer and plan information in HPT data would make these data more useful. However, we are unaware of suitable standardized plan and payer identifiers, much less ones that are routinely available to hospitals, so hospitals may be unable to report such information, at least without incurring large administrative costs. As an incremental step, CMS could consider requiring hospitals to report a standardized market-segment or line-of-business field, which should be more feasible and still useful to data users. More generally, we note that there is substantial overlap between the HPT data and insurers’ Transparency in Coverage (TiC) data, and as the TiC data improve, the policy rationale for robust HPT reporting will likely weaken.

Read the full comment letter here