The AAFP recently took advantage of another opportunity to provide CMS with suggestions for improving Medicare's 2017 hospital outpatient prospective payment system and ambulatory surgical center payment system final rule.
The final rule(www.gpo.gov) was published in the Nov. 14 Federal Register and left open the option for further comment from stakeholders.
Even though the final rule included elements the AAFP had previously recommended, such as increased flexibility for physicians who participate in the Medicare and Medicaid Electronic Health Record Incentive programs, as well as removal of pain management questions from a consumer assessment survey of hospital care received, the AAFP still was troubled by certain outstanding issues.
Those issues were the focus of a Dec. 21 letter(3 page PDF) to CMS Acting Administrator Andy Slavitt that was signed by AAFP Board Chair Wanda Filer, M.D., M.B.A., of York, Pa.
The Academy noted its support for CMS efforts to align payment policies for physicians in independent practice with those for physicians whose practices have been purchased by a hospital, and said policies finalized in the rule would level the "economic playing field" for independent practices and be fair to Medicare beneficiaries.
However, the AAFP urged CMS to stop paying more for services provided in an inpatient, outpatient or ambulatory surgical center setting than it does for the same services provided in a physician's office.
The AAFP again encouraged CMS to "create incentives for services to be performed in the most cost-effective location," which often is the physician's office.
CMS noted in the final rule that in 2017 and 2018, it would not ensure equal payments for the same services regardless of site of service.
"That means hospitals may still be incentivized to buy physician practices based on the mix of services they provide and bill for them as PBDs (provider-based departments) at Medicare rates higher than would have been paid had the practice not been bought," said the AAFP.
This practice "encourages hospitals to make business decisions that run counter to the public interest and the goals of the Medicare program," the Academy continued.
To equalize payment rates between physician offices and non-excepted off-campus PBDs on a procedure-by-procedure basis, the AAFP urged CMS to pay off-campus PBDs for their non-excepted items and services based on Medicare physician fee schedule rates.
The letter provided examples of how payment for other services for which CMS does not provide separate payment under the fee schedule would be calculated.
Equalizing payment rates in this fashion "is consistent with the AAFP's vision for how Medicare payment should be designed," concluded the AAFP.
Related AAFP News Coverage
2017 Outpatient Prospective Payment System
AAFP Savors Successes Achieved in Final OPPS Rule