On October 5th, the HFSA submitted comments in response to the calendar year (CY) Centers for Medicare and Medicaid Services (CMS) Hospital Outpatient Prospective Payment System (OPPS) proposed rule.  The focus of the letter was on the Agency’s proposal to eliminate what is referred to as the “Inpatient Only” (IPO) list, which designates procedures that are payable only in the inpatient setting. CMS states that its intent is to allow the physician to select the most appropriate site-of-service.  However, with over 1,700 procedures on the IPO, the HFSA urged the Agency to move with caution and to take a more patient-centered approach that also considers the reactions that payers might have to attempt moving procedures to a perceived less-costly site-of-service.

In the event the policy is finalized, the HFSA also asked CMS to extend the period of time for which providers would be subject to site-of-service audits and reviews for procedures moved off of the IPO list to ensure that it is truly shared decision-making between the patient and physician that is driving the selection of the site-of-service rather than payer or other system pressures. The OPPS final rule is typically expected around November 1st; however, because of the COVID-19 public health emergency, the Agency has signaled the final rule might be delayed until early December (with a January 1, 2020) effective date.