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Premier Submits Comments on CY 2022 Medicare Outpatient Proposed Rule

Premier submitted final comments in response to the Centers for Medicare & Medicaid Services (CMS)’ proposed CY 2022 rule for the outpatient prospective payment system (OPPS). In its comments, Premier strongly opposes CMS’ proposal to increase civil monetary penalties for noncompliance with hospital price transparency requirements. Instead, Premier recommends that CMS:

  • Employ a multistakeholder working group, including both hospitals and insurers, to improve standardization of machine-readable files and alignment with insurers’ price transparency requirements;
  • Work with stakeholders to identify ways to improve accessibility to price transparency data and address perceived barriers through provider education and subregulatory guidance;
  • Recognize challenges that hospitals face in maintaining price estimator tools and maintain flexibility in how hospitals can meet requirements; and
  • Establish different framework for reporting value-based arrangements.

Additionally, Premier recommends the following changes to the Radiation Oncology model design to ensure providers have the necessary supports and flexibilities to succeed under the model and that beneficiaries’ access to care is maintained:

  • Incorporate opportunities for upside risk under the model
  • Reduce discounts under the model to no more than 3 percent
  • Establish an implementation year to allow CMS and participants time to work through technical challenges
  • Adopt additional adjustments to ensure adequate payment
  • Modify measures to reduce provider burden

Finally, Premier continues to oppose CMS’ ongoing cuts under the 340B drug discount program, which continue to harm our nation’s safety net hospitals and are inconsistent with the administration’s commitment to health equity.

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