NCHA Submits Comment Letter Addressing OPPS Proposed Rule

The North Carolina Healthcare Association (NCHA) submitted the attached comment letter addressing the Calendar Year 2019 hospital outpatient prospective payment system (OPPS) proposed rule on Monday, September 20, 2018. We focused our comments on the proposal to limit expansion of services in excepted off-campus provider-based departments (PBDs), the proposed reduction in payment for hospital outpatient clinic visit in excepted off-campus PBDs, the proposal to apply the 340B Drug Payment Policy to non-excepted PBDs, and decoupling the inpatient prospective payment system and OPPS wage index for the rural floor calculation. We also responded to CMS’s Request for Information on price transparency.

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