Comments to CMS on a 2022 Proposed Hospital Outpatient Rule Impacting Site of Service and Health Equity

The Business Group submitted comments on a proposed rule (CMS-1753-P) urging CMS to reconsider its policy direction on site of service and improve health equity.

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September 17, 2021

Specifically, the Business Group:

  • Encouraged CMS to reconsider phasing out the inpatient only list. Instead, we recommended a longer phase in period and rigorous evaluation.
  • Encouraged CMS to add the procedures identified in a 2021 rule to covered list for ambulatory surgical centers with an appropriate phase in period.
  • Recommended CMS adopt a consistent data collection system across all settings to accurately track health outcomes stratified by race, ethnicity, socio-economic factors and more.

Comments to CMS on a 2022 Proposed Hospital Outpatient Rule Impacting Site of Service and Health Equity

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