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Learn about policy issues important to medical schools and teaching hospitals, with Executive Vice President Atul Grover, M.D., Ph.D.

Washington Highlights

AAMC Responds to House Energy and Commerce Committee on Site-Neutral Payments

February 19, 2016—The AAMC Feb. 19 sent a comment letter in response to the House Energy and Commerce Committee’s request for feedback on various technical fixes to address the site-neutral payment policy included in Section 603 of the Bipartisan Budget Act of 2015 (P.L. 114-74) [see Washington Highlights, Dec. 18, 2015].

Under current law, beginning on Jan. 1, 2017, any new off-campus hospital outpatient departments (HOPDs) must bill under the physicians fee schedule (PFS) or ambulatory surgical care payment system (ASCPS) rather than the outpatient prospective payment system (OPPS).

In the letter, AAMC Chief Public Policy Officer Atul Grover, M.D., Ph.D. highlights the disproportionate impact of site-neutral payment policies and warns that the provisions are “counter-productive and could lead to the closure of some teaching hospital HOPDs and the reduction of services in others, greatly affecting vulnerable populations – especially those with complex medical problems – that receive care there, and limits the ability to train the next generation of health professionals in these outpatient settings.”

The AAMC proposes several areas of concern be addressed through a technical correction, including:

  • Appropriately accounting for differences in the patients treated, services provided, and regulatory burden at HOPDs, compared to physician offices;
  • Disproportionate impact of proposed “equalizations” on the nation’s teaching hospitals and the need for further studies to assess impact on access to care and the training of the future physician workforce, prior to implementation;
  • Limiting the key setting for outpatient residency training and availability of care to patients;
  • Issues of regulatory concern including grandfather provisions; and
  • Addressing the “off-campus” hospital definition to consider growth for institutions facing unavailability of contiguous land.

Finally, the AAMC urges Congress to “pursue a legislative technical correction that would define ‘under-development’ HOPDs, expand the grandfather provision to include those sites, and direct CMS to work with the hospital community to answer the many regulatory questions related to implementation of Section 603.”


Len Marquez
Director, Government Relations
Telephone: 202-862-6281

Courtney Summers
Senior Legislative Analyst
Telephone: 202-862-6042


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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806