Alliance for Site Neutral Payment Reform Applauds Proposed OPPS Rule

Advocacy group urges CMS to continue implementation of site neutral payments for outpatient clinic visits.

Washington, DC, September 30, 2019 --( The Alliance for Site Neutral Payment Reform submitted comments to the Centers for Medicare & Medicaid Services (CMS) on September 27 in support of a provision to continue implementation of site neutral payments for outpatient clinic visits in the Calendar Year (CY) 2020 Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems proposed rule (CMS-1717-P).

For 2020, CMS is proposing to continue the two-year phase-in of site neutral payments for Evaluation and Management (E/M) services – one of the most common clinic services. This policy will apply the Physician Fee Schedule (PFS) equivalent rate for E/M services when provided at an off-campus hospital outpatient department (HOPD) that currently bills Medicare under the OPPS. The agency estimates this provision will result in an estimated $810 million in savings for the Medicare program and taxpayers in 2020.

“The Alliance applauds CMS for its continued commitment to site neutral payment reform in the 2020 proposed rule and strongly supports its efforts toward ensuring the exact same service is reimbursed at the same rate despite the setting,” the letter states. “The Alliance fully supports this proposal and encourages CMS to continue exploring opportunities to implement site neutral payments for all clinically appropriate outpatient services.”

The Alliance noted that the current payment differential between the OPPS and the PFS incentivizes hospitals to acquire freestanding physician practices to gain access to higher reimbursement rates. It praised the Administration for its attention to the negative consequences this payment disparity has on patient access to care and consolidation in the health care marketplace and urged CMS to examine other opportunities to equalize payment rates, such as chemotherapy administration, imaging procedures, and certain cardiology, orthopedic, and gastroenterology services.

Site neutral payments generate significant healthcare savings that directly and positively impact beneficiaries, the Medicare program, employers and American taxpayers, in addition to enhancing transparency for patients. According to CMS, site neutral payments for Evaluation and Management (E/M) services are expected to save the Medicare program an estimated $650 million and lower patient co-payments by $160 million in 2020.

The full text of the Alliance’s comment letter can be read here.

About the Alliance for Site Neutral Payment Reform
The Alliance for Site Neutral Payment Reform is a coalition of patient advocates, providers, payers and employers who support payment parity across site of service in order to decrease Medicare and commercial spending, ensure patients receive the right care in the right setting, lower taxpayer and beneficiary costs and increase patient access. Our growing membership represents healthcare providers, patient and consumer groups, insurers and others who believe patients – and the healthcare system – would be better served by policies that are fiscally wise and preserve and enhance care options. Learn more at
Alliance For Site Neutral Payment Reform
Ellen Almond