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Premier Comments on Proposed Outpatient Payment Rule

September 5, 2012
by Gabriel Perna
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In recently submitted comments, the Charlotte-based Premier alliance urged the Centers for Medicare & Medicaid Services (CMS) to make changes to outpatient payment policies and quality measure reporting proposals issued in July. Responding to the outpatient prospective payment proposed rule, healthcare network  systems alliance voiced strong support for CMS’ proposal to reimburse hospitals for separately payable drugs and biologicals using the statutory default rate. 

The statutory default rate is based on the method used for drugs furnished in the physician’s office, which is Average Sales Price (ASP) + 6 percent. Responding to CMS’ request for comments on policy changes around outpatient observation status, Premier shared an analysis it jointly conducted with the National Association of Public Hospitals which showed that changing trends in these services are appropriate.  Premier recommended instead that CMS provide education to physicians on the changing trends in the standard of care and provide guidance encouraging them to consider inpatient admission rather than rely on extended observation.

While supporting the proposed rule’s adoption of criteria to determine when quality measures are retained and removed from the Hospital Outpatient Quality Reporting (OQR) program, Premier urged CMS to remove six measures from the program to align with the National Quality Forum’s Measure Applications Partnership recommendations.  Premier reiterated its long-standing position that CMS avoid adopting measures before they have been thoroughly specified and tested. In addition, Premier commended CMS for its decision to maintain, rather than expand, the current measure set for the ambulatory surgical center quality reporting system until providers gain experience with the program.

To ensure that the Medicare EHR Incentive Program 2012 Reporting Pilot adequately tests the measures and processes, Premier recommended that CMS finalize its proposal to extend the pilot for another year and continue to work with vendors to ensure all types of hospitals are included in the testing.

Full comments can be found here:



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