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  • Washington Highlights

    AAMC Comments on CY 2024 OPPS Proposed Rule


    Mary Mullaney, Director, Hospital Payment Policies
    Phoebe Ramsey, Director, Physician Payment & Quality
    Katherine Gaynor, Hospital Policy and Regulatory Analyst
    For Media Inquiries

    On Sept. 8, the AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the calendar year (CY) 2024 Outpatient Prospective Payment System (OPPS) proposed rule.

    Among the comments provided to the agency, the AAMC asked for an increase to the OPPS market basket update to account for increased labor and supply costs. The AAMC also expressed support for the proposal to create an add-on payment for hospitals to establish and maintain a “buffer stock” of expensive, essential medicines.  

    The association encouraged the agency to finalize its proposals related to adding certain dental codes eligible for reimbursement under the OPPS. The letter noted support for the proposal to align OPPS payment rates for Intensive Cardiac Rehabilitation services furnished at nonexcepted off-campus, provider-based departments. The AAMC also supported the adoption of the Intensive Outpatient Program for Medicare Part B beneficiaries and provided comments on the payment methodology and covered services proposals.

    In response to several changes to measures in the Outpatient Quality Reporting Program, the AAMC asked that the CMS reconsider measure specifications prior to adopting a new procedural volume indicator and not to finalize proposed modifications to the COVID-19 vaccination rate among health care personnel until there is greater clarity around booster doses that might support annual reporting similar to the influenza vaccination measure. The comments also requested that the agency adopt the Excess Radiation Dose/Inadequate Image Quality electronic clinical quality measure as an optional measure hospitals may choose to report under the Outpatient Quality Reporting Program and to remove measure OP-22 from the program.