The American Hospital Association on Sept. 17 submitted its comments on CMS’ Outpatient Prospective Payment System proposed rule for 2022, strongly opposing stiffer penalties for price transparency noncompliance and supporting the agency’s decision to keep the inpatient-only list.

CMS unveiled the proposed rule July 19. Below are six key takeaways from the American Hospital Association’s comments:

  1. The AHA urged CMS not to finalize the proposed penalty increases for price transparency noncompliance. It asked the agency to “instead focus on aligning the various federal price transparency policies to better serve patients and reduce duplication of effort.”

  2. The AHA supports CMS’ proposal to halt the elimination of the inpatient-only list.

  3. The AHA supports CMS’ proposals related to the Outpatient Quality Reporting and ASC Quality Reporting programs.

  4. The AHA supports CMS’ proposal to reinstate the criteria for adding surgical procedures to its ASC covered procedures list. It also supports CMS’ related proposal to remove 258 procedures it had added to the list in 2021.

  5. The AHA opposed the CMS’ OPPS payment cuts to 340B hospitals, saying “these cuts directly harm 340B hospitals and their ability to care for their patients, contravening Congress’ intent in establishing the 340B program.”

  6. CMS proposed  continuing to pay for hospital outpatient clinic visit services in excepted off-campus provider-based departments at 40 percent of the OPPS payment amount. The AHA urged CMS to reinstate full OPPS payment for those visits, saying “CMS has undermined clear congressional intent and exceeded its legal authority.”