Statement on the CY 2020 OPPS Proposed Rule

By Blair Childs, Senior Vice President of Public Affairs, Premier

Premier opposes CMS’ continuation of Medicare site-neutral payments that will reduce payment for outpatient clinic visits by 60 percent. We believe CMS should factor in the mandatory requirements on outpatient clinics, such as 24/7 standby emergency department services, disaster preparedness, myriad regulatory requirements, and the provision of care to all that need treatment regardless of ability to pay. These requirements result in greater overhead expenses for provider-based outpatient clinics. Rather than micromanage payment and direct settings of care, CMS should focus its changes on incenting the movement to value-based care and risk-based models, providing incentives for health systems to manage care and provide services in the least costly setting.

Premier continues to oppose the 28.5 percent payment cut for 340B drugs. CMS’ decision to apply these cuts in 2020 is especially alarming given the federal district court’s ruling that the 2018 and 2019 cuts to 340B payments were unlawful.

Premier is committed to quality and price transparency. We are, however, concerned with requirements to publicly post standard charges and payer-specific negotiated rates. This policy fails to address consumers’ information needs to truly understand price, including information on copays and deductibles. Moreover, disclosing payer negotiated rates harms health systems’ negotiating power, creating anti-competitive market distortions.