NAUH LogoThe National Association of Urban Hospitals has submitted extensive comments to the Centers for Medicare & Medicaid Services on the agency’s proposal to implement site-neutral payment policies for Medicare-covered outpatient services.

In its comments, NAUH raises objections to:

  • how the proposed rule addresses the relocation of existing hospital-based outpatient departments;
  • how it addresses the expansion of services at existing departments;
  • how it proposes addressing the sale of existing departments; and
  • how it could affect such departments’ future eligibility in the section 340B prescription drug discount program.

Last year’s Bipartisan Budget Act called for Medicare to pay providers for outpatient services on a site-neutral basis.  The proposed rule constitutes CMS’s response to that law.

To see NAUH’s entire comment letter, go here.