July 11, 2016
As part of the CY 2017 proposed Hospital Outpatient Prospective Payment System rules (OPPS) the Centers for Medicare and Medicaid Services (CMS) released the long awaited proposed payment changes for items and services furnished from off-campus provider-based hospital outpatient departments (Proposed Rule). 

These proposed payment changes were necessitated by Congress’s passage of Section 603 of the Bipartisan Budget Act of 2015 (Section 603) last fall and evince CMS’ exceptionally narrow interpretation of that provision and threaten the ability of hospital providers to continue growing and expanding existing outpatient service capabilities, thereby constraining the services available to Medicare beneficiaries. Reshaping the Proposed Rule will take a concerted stakeholder effort, so we encourage all hospitals and interested stakeholders to submit comments to CMS. Moreover, to the extent you have any projects under development that would be impacted by the Proposed Rule, if finalized, or projects that are on hold as a result of Section 603, we strongly encourage you to reach out to Polsinelli so that we may assist you in developing a strategy to approach CMS and/or Congressional representatives to ensure your concerns are heard.

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