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AAMC Submits Comments on the CY 2013 OPPS Proposed Rule

September 7, 2012—The AAMC Aug. 31 submitted comments  to the Centers for Medicare and Medicaid Services (CMS) on the calendar year (CY) 2013 hospital outpatient prospective payment system (OPPS) proposed rule. CMS will implement final changes to the OPPS on Jan. 1, 2013.

The AAMC comment letter expresses concerns with the CMS’s proposal to use the geometric mean, instead of the median, to determine ambulatory payment classification (APC) relative weights. While the AAMC supports changes to improve the accuracy of OPPS payments, there is concern that this change would not be budget neutral as CMS has claimed. The AAMC also cautions that changes to the APC weighting methodology may have a disproportionately negative effect on major teaching hospitals.

The AAMC supports the agency’s willingness to open a dialog on the issue of inpatient versus outpatient status. CMS noted concerns in the proposed rule that the current policy may provide insufficient reimbursement for care that hospitals provide to certain patients, and that hospitals have increasingly used outpatient observation status to avoid denials of inpatient stays upon contractor review. The AAMC comment letter recommends that CMS engage stakeholders in a broader discussion of policy options to address this issue and encouraged CMS not to adopt any new final policies in this year’s OPPS final rule.

Regarding the quality provisions outlined in the proposed rule, the AAMC commends CMS for not expanding the OQR program at this time. However, the association urges CMS adopt the Measure Applications Partnership’s (MAP) recommendations and remove seven non-NQF-endorsed measures from the Outpatient Quality Reporting (OQR) program.

In other areas, the AAMC comment letter opposes the proposal to move knee replacements off the inpatient-only list, supports proposed cancer adjustment policy, and commends CMS for proposing to adopt a payment rate of Average Sales Price (ASP) plus 6 percent for separately payable drugs and biologicals. The AAMC also expresses concern regarding CMS’s proposed changes to payments for proton beam therapy and questioned the sufficiency of a proposed payment adjustment for technetium-99.


Jennifer Faerberg, MHSA
Director, Clinical Transformation Unit
Telephone: 202-862-6221


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