aamc.org does not support this web browser.
  • Washington Highlights

    AAMC Comments on Hospital Transparency, Site-Neutral Legislation

    Sinead Hunt, Legislative Analyst
    For Media Inquiries

    On May 3, the AAMC submitted comments on a legislative package under consideration by the House Energy and Commerce Committee. The Health Subcommittee previously considered the package, which includes 17 bills aimed at increasing transparency and reducing consolidation across the health care sector, during an April 26 hearing [refer to Washington Highlights, April 28]. The package includes proposals to implement so-called site-neutral payment policies in the Medicare program, eliminate scheduled cuts to the Medicaid disproportionate share hospital (DSH) program, establish additional oversight and transparency mechanisms in the 340B Drug Pricing Program, and require additional reporting by hospitals.  

    In a letter to committee leadership, the AAMC reiterated its support for the Supporting Safety Net Hospitals Act (H.R. 2665). Co-sponsored by Reps. Michael Burgess, MD (R-Texas), Dan Crenshaw (R-Texas), Diana DeGette (D-Colo.), and Yvette Clarke (D-N.Y.), this AAMC-endorsed legislation would address scheduled reductions to the Medicaid DSH program, which are due to go into effect on Oct. 1. The AAMC has repeatedly advocated for Congress to either delay or eliminate these cuts, including most recently in a group letter to congressional leadership [refer to Washington Highlights, March 10]. The letter described the myriad financial challenges facing safety-net hospitals, including workforce shortages and inflation, emphasizing that “now more than ever, the nation’s safety net cannot withstand additional cuts.”  

    The AAMC also emphasized its opposition to legislation that would implement so-called site-neutral payment policies in the Medicare program, outlining the real differences between hospital outpatient departments (HOPDs), physician offices, and ambulatory surgical centers. The letter cited HOPDs’ additional licensing, accreditation, and regulatory requirements, as well as the social and medical complexity of patients treated in these settings, as justification for differences in reimbursement. The association expressed concerns that the proposals under consideration would disproportionately impact teaching hospitals, thereby reducing access to care for Medicare beneficiaries and limiting trainees’ exposure to primary care and ambulatory services. “Expanding site-neutral cuts could jeopardize access to care for Medicare beneficiaries, especially the most medically complex,” the letter warned.  

    The AAMC also noted concerns regarding legislative proposals that would increase the regulatory and administrative burden on hospitals, particularly those participating in the 340B Drug Pricing Program. The letter underscored the association’s opposition to a discussion draft introduced by Rep. Larry Bucshon, MD, (R-Ind.), which would authorize the secretary of the Department of Health and Human Services to audit how covered entities use their 340B savings, as well as require hospitals to report comprehensive financial data. The letter noted that “this legislation would misrepresent the value of the 340B program accrued to hospitals,” differentiating the “net revenue” generated from the 340B program from an organization’s “340B savings.” The AAMC also cited concerns that the proposal would require 340B hospitals to stratify reporting by child site, which would “necessitate entirely new software systems.” The AAMC concluded, “As 340B hospitals grapple with unprecedented financial challenges, we urge Congress to reconsider this legislation, which would impose an additional administrative burden on hospitals, thereby diverting time and resources from patient care.”