On September 6, KHA submitted comments to the Centers for Medicare and Medicaid Services on the calendar year (CY) 2017 hospital outpatient prospective payment system (OPPS) proposed rule that would implement site-neutral provisions of the Bipartisan Budget Act of 2015 (BiBA).

Kentucky's hospitals are opposed to CMS' site-neutral proposal because the rule would not only apply to new off-campus outpatient facilities but also to existing hospital outpatient departments (HOPDs) that expand services or relocate to benefit their communities by lowering payment.

For a full copy of KHA's comments, members may visit the Policy page of the Advocacy section of www.kyha.com.

If you have any questions, please contact Nancy Galvagni at KHA (ngalvagni@kyha.com).

Last week, KHA expressed serious concern with certain aspects of the Centers for Medicare and Medicaid Services’ (CMS) proposal for implementing a site-neutral payment component to the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) for cost reporting periods beginning on or after October 1, 2015.

“KHA supports many of CMS’s proposals, such as the proposal to use a specific 15 Medicare-severity-LTC-diagnosis-related groups to identify the psychiatric and rehabilitation conditions that would be paid a site-neutral rate versus a standard LTCH PPS rate, and KHA supports the proposal to use the previously finalized pressure ulcer measure to meet IMPACT Act requirements,” wrote KHA Membership Services Director Pam Kirchem, commenting on LTCH provisions of the proposed inpatient and LTCH PPS rule for fiscal year 2016. “However, we believe that the proposed two outlier-related budget neutrality adjustments are unwarranted and result in inappropriately lower LTCH payments. We recommend CMS calculate...