The letter also expressed concern about removal of higher hospital-level differentials for 71 ambulatory payment classifications, or MedPAC's recommended "site-neutral payment policy." Currently, some services may be billed at much higher rates if they are performed in a hospital outpatient department (HOPD) rather than in a clinician's office.
"HOPDs are different from physician offices and provide a wide range of essential acute-care and diagnostic services, support public health needs, and provide access to care to vulnerable patient populations that is not otherwise available in the community," Fishman wrote. "They also provide 24/7 access to emergency care and standby capacity for emergency response that is not separately funded and must be built into payments for all services."
For example, the payment for one particular procedure, a Level II echocardiogram without contrast, would be cut 67% over what is paid this year, cutting reimbursement for that one service by $275 million.
Level III nerve injections would be cut by 32%, representing a cut of $108 million, and Level II neuropsychological testing would be cut by 86%, representing a cut of $1.9 million.
Another category of payment change Fishman included is for documentation and coding cuts.