Internists Applaud CMS for Supporting Site-Neutral Payment

Statement attributable to:
Ana María López, MD, MPH, FACP
President, American College of Physicians

Washington, DC (July 27, 2018) — The American College of Physicians (ACP) is encouraged by provisions included in the Outpatient Prospective Payment System (OPPS) & Ambulatory Surgical Center (ASC) proposed rule that supports site-neutral payment that was released by the Centers for Medicare and Medicaid Services (CMS) on July 25.

To increase the sustainability of the Medicare program and improve quality of care for seniors, CMS is moving toward site-neutral payments for office visits provided in outpatient clinics (clinic visits are the most common service billed under the OPPS). Currently, CMS often pays more for the same type of office visit in the hospital outpatient setting than in the physician office setting, resulting in higher out-of-pocket costs to patients and unnecessary spending by Medicare.

ACP agrees with CMS that there is no justification for patients and the Medicare program paying more for a visit to a doctor when the service is provided in an office owned by a hospital than it would for the same type of visit in an independent physician practice. Such additional “facility fee” add-on payments do not result in better service or value to the patient.

If finalized, this proposal is projected to save patients about $150 million in lower copayments for clinic visits provided at an off-campus hospital outpatient department. CMS is also proposing to close a potential loophole through which hospitals are billing patients more for visits in hospital outpatient departments when they create new service lines.

ACP is a founding member of the Alliance for Site Neutral Payment reform and has long called for policies that would level the playing field in payments for services in outpatient departments, and in physician practices owned by hospitals, and equivalent services provided in independent physician practices.

ACP welcomes improvements made in this proposed rule, and we are particularly encouraged by the actionable steps being taken to support site-neutral payment. ACP is pleased to see CMS incorporate several recommendations that are in line with ACP policy in the proposed rule, including:

  • An increase in the number of policies that reduce payment differences between sites of service, and adding services to the ASC covered procedures list.
  • Removal of 15 measures that ASCs and outpatient departments are required to report under their respective quality programs, as part of its meaningful measure initiative and in line with fee schedule changes. This is aligned with ACP’s goal of reducing documentation burdens through our Patients Before Paperwork initiative.  
  • Requests for Information on price transparency, a Medicare Part B drug model, and their Advancing My HealthEData initiative.

ACP will be examining the rules more closely and submitting comments to CMS on both rules with our suggestions for improvements.


About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 154,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter and Facebook.

Contact: Julie Hirschhorn, (202) 261-4523,