NASH has submitted formal comments to the Centers for Medicare & Medicaid Services in response to that agency’s proposed 2021 Medicare outpatient prospective payment system rule.

That rule describes how CMS proposes paying hospitals for Medicare-covered fee-for-service outpatient care in 2021.

Writing on behalf of private safety-net hospitals, NASH addressed the following aspects of the proposed rule:

• Proposed rate increase.   NASH endorsed CMS’s proposal to raise Medicare fee-for-service rates for outpatient care.
• The 340B program.  NASH expressed strong opposition to CMS’s proposal to reduce  reimbursement for prescription drugs to 340B-eligible hospitals.
• Phase-out of the inpatient-only services list.  NASH asked CMS not to phase out the inpatient-only services list.
• Changes in the level of supervision for selected outpatient therapeutic services.  NASH conveyed its support for proposed reductions in such supervision.
• The physician-owned hospital exception.  NASH opposed CMS’s proposal to ease the current limit on the expansion of high-Medicaid physician-owned hospitals.

Learn more about NASH’s reasoning behind each of these positions in its letter to CMS on the proposed 2021 Medicare outpatient prospective payment system regulation.