5 Issues to Know About Medicare Web site-Impartial Fee Reforms | KFF

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Five Things to Know About Medicare Site-Neutral Payment Reforms | KFF

Amid rising considerations about well being care spending and voters’ worries about well being care affordability, there’s rising, bipartisan curiosity in proposals to align Medicare funds for outpatient providers throughout care settings, in any other case often called “web site impartial” funds. The objective of this method could be for Medicare to pay the identical charge for a similar service, whether or not it’s offered in a hospital outpatient division (HOPD), ambulatory surgical heart (ASC), or freestanding doctor workplace, topic to affected person security and high quality safeguards. Non-public payers may additionally obtain financial savings in the event that they undertake related fee insurance policies. Policymakers have been focusing not too long ago on site-neutral fee reform in response to considerations about well being care prices and the speedy tempo of consolidation, on condition that the variations in fee throughout settings for a similar service create a monetary incentive for hospitals to accumulate doctor practices.

Web site-neutral fee reforms would decrease prices by lowering the quantity Medicare pays for sure providers when performed in dearer settings and will additionally decrease prices by lowering incentives for hospitals to purchase up doctor practices, a sample which has additionally been related to greater industrial costs. By way of laws and rulemaking, Medicare has moved incrementally forward by aligning funds for clinic visits offered at off-campus HOPDs and for all different providers offered at off-campus HOPDs that began billing on or after November 2, 2015, with some exceptions. Some policymakers are urgent to broaden the attain of site-neutral fee reforms to incorporate further settings, resembling on-campus HOPDs and off-campus HOPDS that had been grandfathered and exempted from sure site-neutral funds below present legislation. In December 2023, for instance, the Home of Representatives handed the Lower Costs, More Transparency Act on a bipartisan foundation, which might align Medicare funds for drug administration providers in off-campus HOPDs, together with these exempt below prior reforms.

Opponents, principally within the hospital business, argue that site-neutral fee reforms would adversely have an effect on sufferers’ entry to providers by lowering hospital revenues, elevating explicit considerations about entry for rural and low-income populations. Additionally they counsel that the upper funds for providers in hospital outpatient settings are justified by the extent of care sufferers want, the upper prices of offering care in hospitals (e.g., because of regulatory necessities), and the prices of sustaining emergency care and standby capability.

This difficulty temporary describes 5 issues to find out about Medicare site-neutral fee reforms for outpatient providers. It doesn’t focus on a associated set of proposals to control outpatient facility charges charged by hospitals and different institutional suppliers in industrial markets, resembling a bill launched within the Senate. These choices are meant to realize related coverage targets however are extra sophisticated, partially, as a result of costs in industrial markets are decided via negotiations between payers and suppliers slightly than being set by the federal government.

1. Medicare typically pays extra for a similar service when offered in a hospital outpatient division versus different settings

Conventional Medicare typically pays extra for outpatient providers when offered in HOPDs than in ASCs or freestanding doctor workplaces—which is often the least-expensive setting. For instance, one report estimated that funds for preliminary preventive exams had been 51 p.c greater in 2023 when offered in an HOPD than in a freestanding doctor workplace, primarily based on nationwide fee quantities. Another estimated that common reimbursement for drug administration providers was 129 to 211 p.c greater in HOPDs than in freestanding doctor workplaces in 2021. (Each units of quantity exclude HOPDs which might be topic to current site-neutral reforms).

Medicare typically pays the identical quantity for providers offered by HOPDs whether or not the HOPD is on the principle campus of the hospital—i.e., “on-campus”—or off-campus. Off-campus HOPDs typically resemble doctor workplaces and will have beforehand been freestanding doctor workplaces that had been acquired by a hospital.

Conventional Medicare Fee System for Outpatient Providers by Care Setting*

Hospital outpatient division (HOPD). Beneath the usual reimbursement method, Medicare makes one fee to the hospital below the outpatient potential fee system (OPPS)—typically known as a “facility payment”—and a separate fee to clinicians utilizing the doctor payment schedule (PFS) charge for facility settings. Some hospitals are excluded from the OPPS, resembling vital entry hospitals (CAHs), which obtain cost-based reimbursement.

Ambulatory surgical heart (ASC). Medicare typically makes use of the same method to reimburse providers offered in ambulatory surgical facilities (ASC) because it does for providers offered in HOPDs however with a facility payment that’s decrease than the OPPS charge.

Freestanding doctor workplace. Medicare makes a single fee to the clinician utilizing the doctor payment schedule (PFS) charge for nonfacility settings.

*Conventional Medicare makes use of the identical fee system throughout settings for outpatient remedy providers, mammography checks, dialysis providers, and scientific lab checks. Supplier reimbursement below Medicare Benefit is negotiated between plans and suppliers, will not be public, and will or might not differ from conventional Medicare charges.

Variations in Medicare funds throughout settings lead to greater prices for Medicare and its beneficiaries. Variations in Medicare funds imply that, by definition, program spending is greater than it might have been if this system reimbursed for providers primarily based on the least-expensive setting. Increased Medicare spending results in greater Half B deductibles and cost-sharing quantities in conventional Medicare. For instance, MedPAC estimated that aligning Medicare fee charges for a set of outpatient service classes (described under) would have decreased complete conventional Medicare Half B spending by $6.0 billion in 2021 and beneficiary value sharing by $1.5 billion. Increased Half B spending would additionally contribute to greater premiums for beneficiaries, as a result of Medicare premiums are based on total Part B spending.

Financial savings for beneficiaries attributable to site-neutral fee reforms would range, partially, relying on the quantity of outpatient providers they use and the place they obtain their care. For example, one recent study estimated that aligning reimbursement for drug administration providers between off-campus HOPDs and freestanding doctor providers would have decreased value sharing for conventional Medicare beneficiaries by about $1 on common in 2021 however $1,055 amongst beneficiaries with the best use of chemotherapy who obtain care at off-campus HOPDs that aren’t topic to current site-neutral reforms (along with lowering the usual Half B premium by about $1).

As with Medicare, costs paid by personal plans for outpatient providers also can range throughout care settings. Analysis from the Blue Cross Blue Protect Affiliation found that common costs paid for a big industrial inhabitants had been 31% greater for clinic visits in 2022 when offered in an HOPD versus a freestanding doctor workplace, 238% greater for chest x-rays, and 563% greater for prostate biopsies, amongst different variations. These variations may partially replicate Medicare’s reimbursement system to the extent that industrial payers are benchmarking to Medicare charges.

Increased industrial costs attributable to variations in funds by web site of care result in greater prices for employers, greater premiums and value sharing for staff and different well being plan enrollees, and doubtlessly greater spending or decrease revenues for the federal authorities. A CBO report discussing insurance policies to cut back industrial costs said that they might “would primarily have an effect on the funds by decreasing federal subsidies for medical health insurance.”

Increased Medicare funds for providers offered in HOPDs than in freestanding doctor workplaces create a monetary incentive for hospitals to accumulate doctor practices, which may result in greater prices. Each the CBO and MedPAC have noticed that Medicare’s reimbursement system creates an incentive for hospitals to accumulate doctor practices. Doing so permits suppliers to invoice Medicare on the greater charges for a similar providers when offered in an HOPD, resulting in greater prices. Some research present proof that variations in funds throughout settings have led to will increase in consolidation of doctor practices with hospitals and that consolidation has led to greater spending in Medicare and industrial markets, with unclear results on high quality.

2. Whereas Congress enacted laws in 2015 to align Medicare funds throughout settings in sure circumstances, there’s curiosity in adopting further site-neutral fee reforms

Proponents say that site-neutral fee reforms would cut back Medicare program and beneficiary spending, result in spillover results that cut back spending in industrial markets, and additional lower industrial costs by slowing the tempo of consolidation. By way of laws and rulemaking, Medicare has aligned funds for clinic visits at off-campus HOPDs in addition to for all different providers at off-campus HOPDs that began billing on or after November 2, 2015, with some exceptions. Extra not too long ago, policymakers have expressed some curiosity in making use of these reforms to further providers and settings, primarily based on Congressional hearings and laws that handed the Home of Representatives in 2023.

The Bipartisan Funds Act (BBA) of 2015 launched site-neutral fee reforms for providers offered at comparatively new off-campus HOPDs. Beneath this modification, Medicare started to pay for providers in some HOPDs at a decrease quantity extra intently aligned with what could be paid in a freestanding doctor workplace. The BBA provisions utilized to off-campus HOPDs that began to invoice Medicare below the OPPS on or after the date that the legislation was enacted (November 2, 2015), whereas grandfathering off-campus HOPDs that existed and billed earlier. The BBA of 2015 and subsequent laws (the 21st Century Cures Act of 2016) created further exemptions for off-campus HOPDs, together with for these which might be devoted emergency departments, are associated to a devoted most cancers hospital, or had been below development when the BBA was enacted. Beneath present legislation, exempt off-campus HOPDs are permitted to invoice below the OPPS for brand spanking new providers offered, for instance, because of incorporating further doctor practices.

In 2015, the CBO estimated that the BBA site-neutral fee reforms would save about $9 billion over ten years. CMS carried out this reform by lowering facility charges for affected providers to 50% of OPPS charges starting in 2017 and to 40% starting in 2018, with the intent of aligning fee in these settings with freestanding doctor workplaces.

In apply, this reform has been comparatively modest in scope. In line with MedPAC, providers offered in non-exempt off-campus HOPDs and paid at decrease quantities account for lower than one p.c of all OPPS spending.

In 2019, CMS prolonged Medicare’s site-neutral funds to cowl clinic visits in any respect off-campus HOPDs that submit claims to Medicare below the OPPS. This contains all off-campus HOPDs that had been exempt below the BBA of 2015. CMS decreased the ability part of reimbursement for clinic visits to 40% of OPPS charges, which it meant to part in over 2019 and 2020. Implementation was briefly interrupted when the American Hospital Affiliation (AHA) and others filed a lawsuit towards the Division of Well being and Human Providers, arguing that CMS had exceeded its authority. Nonetheless, a federal appeals court docket rejected the business’s declare in 2020 and the Supreme Courtroom declined to think about an enchantment in 2021, which allowed CMS to totally implement the rule. In 2022, CMS introduced that rural sole neighborhood hospitals could be exempted from this site-neutral fee reform starting in 2023.

Two-thirds of HOPD clinic visits are offered in on-campus HOPDs and so should not topic to the decrease charges.

Given the restricted attain of present site-neutral fee insurance policies, MedPAC and others have beneficial that Congress implement further site-neutral reforms for outpatient providers. MedPAC’s recommendation is that Congress “extra intently align fee charges throughout ambulatory settings for chosen providers which might be secure and acceptable to offer in all settings and when doing so doesn’t pose a threat to entry,” with CMS selecting the providers. MedPAC offered one method that might align HOPD and ASC fee charges with freestanding doctor workplaces for 57 service classes which might be mostly offered in that setting, which the Fee views as a sign that they are often safely offered there. This contains providers resembling clinic visits, drug administration, and sure imaging providers. MedPAC’s method would additionally align HOPD fee charges with ASCs for 9 service classes which might be mostly offered in that setting, resembling sure sorts of colonoscopies. The method would enhance aligned funds when associated to emergency visits or trauma care. Web site-neutral fee reforms have additionally been endorsed by teams from throughout the political spectrum— together with Families USA, Americans for Prosperity, the Bipartisan Policy Center, and former Secretaries of Health and Human Services (HHS) Kathleen Sebelius and Alex Azar—in addition to by the Government Accountability Office and the HHS Office of Inspector General.

In December of 2023, the Home of Representatives handed laws to use Medicare site-neutral funds to medication administered in an outpatient setting. The Home of Representatives handed the Lower Costs, More Transparency Act (320-71) in December 2023, which might align Medicare funds for drug administration providers—resembling for chemotherapy—in off-campus HOPDs with charges for freestanding doctor workplaces. Policymakers have thought of a wide range of different proposals, together with proposals to use site-neutral reforms to cancer diagnosis and treatment services at off-campus HOPDs, all services offered at off-campus HOPDs, or providers offered in any respect HOPDs (off-campus and on-campus) and ASCs when they’re most commonly provided in inexpensive settings, resembling freestanding doctor workplaces (in keeping with the MedPAC method). Former President Trump’s 2021 funds proposal included comparatively broad site-neutral fee reforms (as described under). President Biden didn’t embrace related proposals within the Administration’s budgets for 2022 via 2025.

Regardless of bipartisan curiosity, and a Home-passed invoice, site-neutral fee reforms had been thought of however in the end excluded from a authorities spending package deal that was enacted in March 2024. Proponents are pushing for these reforms to be included in a year-end spending package deal.

3. Web site-neutral fee proposals range in scope, with CBO estimates of financial savings starting from lower than $5 billion to greater than $100 billion over ten years

Estimated financial savings from proposed site-neutral fee reforms range broadly (see Determine 1). For instance, CBO estimated that the availability within the Decrease Prices, Extra Transparency Act that might align funds for drug administration providers in off-campus HOPDs would save $4 billion over ten years. In distinction, of their analysis of former President Trump’s 2021 funds proposal, CBO estimated {that a} proposal to increase reforms to all providers in off-campus HOPDs would have saved $39 billion over ten years. The Trump funds proposal to align funds for on-campus HOPDs for providers generally offered in non-hospital settings would have saved $102 billion over ten years. Variations in financial savings to the federal government would additionally correspond to various financial savings for beneficiaries.

Giant variations in anticipated financial savings replicate the various scope of site-neutral fee reforms:

  • Which internet sites of care are lined? Proposals range primarily based on whether or not they would apply to off-campus HOPDs alone or all HOPDs. Web site-neutral fee reforms for a given set of providers may result in considerably bigger financial savings in the event that they had been additionally utilized to on-campus HOPDs. One study estimated that on-campus HOPDs accounted for 87 p.c of Medicare’s spending on hospital outpatient providers in 2022 and, as famous above, on-campus HOPDs account for two-thirds of clinic visits offered at HOPDs. Another study estimated that aligning funds for the providers recognized by MedPAC would save Medicare $18 billion over ten years if utilized to off-campus HOPDs alone however $127 billion over ten years if on-campus HOPDs had been additionally included.Nonetheless, most reforms have centered on off-campus HOPDs, which can be much less controversial on condition that off-campus HOPDs typically resemble doctor workplaces (and will have been freestanding doctor workplaces that had been acquired by a hospital). Whereas a number of choices would align charges in HOPDs with freestanding doctor workplaces, some would align charges in HOPDs with ASCs and in ASCs with freestanding doctor workplaces for sure providers, leading to further financial savings.
  • What providers could be lined? Proposals range within the providers that might be lined, which in flip impacts the estimated financial savings. For instance, proposals referring to off-campus HOPDs range in whether or not they would align fee for most cancers prognosis and remedy, drug administration (estimated by one group to avoid wasting Medicare $5 billion over ten years), providers mostly offered in inexpensive settings as recognized by MedPAC (estimated to avoid wasting $18 billion over ten years), or all providers (estimated to avoid wasting $28 billion over ten years). Current proposals referring to on-campus HOPDs have centered on providers generally offered outdoors of hospitals. Proposals additionally range by way of whether or not they would carve out or increase funds for providers associated to emergency care or which might be offered in devoted emergency departments.
  • Which suppliers could be given particular consideration or exempted? Proposals range in whether or not they embrace provisions to restrict or offset the influence on sure suppliers, resembling by excluding rural hospitals, capping losses for hospitals that take care of a comparatively massive variety of low-income sufferers, or concentrating on new assets to safety-net or rural hospitals.
  • Are proposals designed to be funds impartial? Web site-neutral fee reforms are sometimes designed to cut back authorities spending however may very well be pursued in a funds impartial method. For instance, MedPAC famous that its suggestion to Congress wouldn’t have a right away impact on complete OPPS spending because of funds neutrality necessities below present legislation, which might lead to offsetting will increase in reimbursement for hospital outpatient providers that aren’t affected by site-neutral reforms. Nonetheless, insurance policies which might be carried out in a funds impartial vogue might nonetheless decrease Medicare spending over time by lowering the inducement for hospitals to accumulate doctor practices.
  • Timing. Proposals range in how shortly they might be carried out and whether or not they could be phased in over time.

Some site-neutral reform proposals would require that off-campus HOPDs present a separate, distinctive identifier from the principle campus when submitting claims, which is predicted to provide modest financial savings. This provision would make it simpler for personal insurers to determine and prohibit facility charges and will enhance the accuracy of Medicare funds to off-campus HOPDs. CBO estimated that one model of this proposal would cut back federal spending by about $2 billion over ten years, primarily via its impact on industrial markets.

4. Opponents say site-neutral reforms would adversely have an effect on affected person care

Critics of site-neutral fee reforms, primarily hospital business representatives, have voiced concern in regards to the doubtless influence on hospital revenues and affected person care. Opponents warn that decreases in Medicare reimbursement attributable to site-neutral reforms could lead on some hospitals to reduce or eradicate providers that they provide in HOPDs or different departments. Simply as reforms may result in financial savings for the federal government and sufferers, they may additionally result in decreases in revenues for hospitals. For instance, MedPAC estimated that its method—i.e., aligning funds for providers offered in on- and off-campus HOPDs and ASCs which might be principally generally offered in less-expensive settings—would cut back Medicare revenues amongst OPPS hospitals by about 3.8% if carried out with out funds neutrality necessities. Critics say that the income losses could be particularly difficult for hospitals in mild of monetary challenges going through the sector, together with greater prices because of labor shortages. Hospital employment now exceeds pre-pandemic ranges, and industry reports point out that funds have been bettering, although some hospitals proceed to wrestle.

Income losses could be bigger for some hospitals than for others. For instance, MedPAC estimated that its method would result in comparatively massive decreases in Medicare revenues for smaller and rural hospitals. Other research has discovered that off-campus HOPDs—the main focus of some reforms—account for a smaller share of complete hospital or facility outpatient revenues in rural versus city areas. Relatedly, based on research supported by the AHA, Medicare beneficiaries handled in HOPDs are extra doubtless than these handled in doctor workplaces to be dual-eligible people.

The potential influence of site-neutral fee reforms on rural hospitals has been a sticking level for some Members of Congress amid broader concerns in regards to the monetary stability of those amenities. As described under, some have proposed choices which might be meant to melt the influence on hospital funds and mitigate entry considerations. Earlier site-neutral fee reforms and plenty of proposals to increase upon these reforms don’t apply to Important Entry Hospitals (CAHs)—that are usually in rural areas—as a result of these amenities are reimbursed by Medicare below a separate fee system.

Critics of site-neutral fee reforms say that greater fee charges for outpatient hospital providers are justified by greater overhead prices (together with these because of stricter regulatory necessities for hospitals) and better prices related to sustaining sure important providers, together with 24/7 emergency care and standby capability for public well being crises and different emergencies. Proponents counter that charges shouldn’t be primarily based on hospital prices however on the prices of offering the service within the least-expensive setting that’s secure and acceptable. Some have proposed to refine funds to offer a mechanism to pay for emergency care and standby providers, slightly than constructing in the price of these providers via greater reimbursement for outpatient providers extra typically.

Opponents of site-neutral fee reforms have additionally advised that reimbursement needs to be greater for HOPDs as a result of they take care of sufferers with extra advanced care wants who’re extra pricey to deal with. For instance, analysis supported by the AHA found that Medicare beneficiaries handled in HOPDs are extra doubtless than these handled in doctor workplaces to have a significant complication and comorbidity or have had a latest emergency division go to or hospital keep. Nonetheless, another analysis discovered that variations in affected person severity throughout HOPDs and doctor workplaces are small. MedPAC has additionally famous that the providers they’ve centered on usually have low complexity—and will not essentially value extra to offer for sicker sufferers—and that hospitals can typically invoice for extra providers below the OPPS if sufferers want them.

As well as, doctor teams and others counsel that Medicare reimbursement charges below the doctor payment schedule—i.e., the idea for aligned fee charges—are insufficient. The preponderance of research finds that Medicare beneficiaries should not have issues accessing clinicians, though the AHA argues that hospital acquisitions of doctor practices have helped protect entry. Some have raised the choice of utilizing financial savings from site-neutral reforms to extend fee charges for physicians, which may assist to mitigate these considerations.

5. Web site-neutral fee reforms may very well be designed to restrict or offset the influence on sure suppliers, resembling rural or safety-net hospitals

To handle considerations in regards to the impact of site-neutral fee reforms on hospital funds and the implications for entry to care and high quality, policymakers may embrace provisions that restrict or offset the influence on weak hospitals, resembling rural or safety-net hospitals. Choices embrace the next:

  • Use financial savings to fund focused help to weak hospitals. Examples of focused help embrace growing reimbursement for rural or safety-net hospitals for providers, delaying scheduled cuts to Medicaid Disproportionate Share Hospital (DSH) funds, growing and bettering the concentrating on of Medicare uncompensated care and DSH funds, extending Medicare fee designations for Medicare Dependent Hospitals and Low-Quantity Hospitals, increasing Medicare Important Entry Hospital (CAH) designations to further amenities, and investing within the rural well being care workforce.
  • Cap losses for weak hospitals. An alternative approach would restrict the discount in Medicare revenues to a specified p.c for any given hospital assembly sure standards (e.g., that take care of a comparatively massive share of low-income beneficiaries) on a short lived or everlasting foundation. One tradeoff of this method is that it might retain among the incentives below Medicare’s present reimbursement system to accumulate doctor practices, because the impact of the reform could be eradicated above the cap. One approach for addressing this is able to be to calculate what the offset would have been previous to implementation after which utilizing that quantity as the idea for future offsets (which might due to this fact not be affected by later acquisitions).
  • Exclude sure hospitals altogether. Earlier site-neutral fee reforms and plenty of proposals to increase upon these reforms don’t apply to CAHs, which accounted for 61 percent of rural hospitals in 2021. Former President Trump’s 2021 funds proposal would have excluded rural hospitals from proposed site-neutral reforms for on-campus HOPDs, with out defining how broadly this exemption could be utilized. Excluding hospitals would cut back the financial savings, though extending the coverage to on-campus HOPDs produces considerably bigger financial savings than insurance policies which might be restricted to off-campus HOPDs. One study estimated that off-campus HOPDs affiliated with rural amenities would account for about six p.c of conventional Medicare program and beneficiary financial savings below the Decrease Prices, Extra Transparency Act’s site-neutral fee reform. The tradeoff of excluding rural hospitals altogether is that it might essentially eradicate the potential advantages of site-neutral fee reform for rural areas, resembling decrease spending for beneficiaries and decreased consolidation.
Key phrases

Ambulatory surgical heart (ASC). ASCs are distinct well being care suppliers that principally present outpatient surgical procedures to sufferers who don’t want to remain in a single day.

Important entry hospital (CAH). Greater than 1,300 hospitals are designated as a CAH by Medicare on the idea of getting 25 or fewer beds and assembly different necessities. Medicare reimburses CAHs primarily based on prices, slightly than below the inpatient or outpatient potential fee programs. CAHs are usually in rural areas.

Facility payment. Charges charged by hospitals and different institutional suppliers that should cowl the operational prices of operating the ability. These are distinct from skilled charges for the care offered by physicians and different well being care professionals.

Freestanding doctor workplace. Freestanding doctor workplaces function independently from a hospital. Providers in freestanding doctor workplaces are reimbursed by Medicare utilizing the doctor payment schedule (PFS). When a hospital acquires a freestanding doctor workplace, the identical providers could be billed below Medicare’s reimbursement system for care offered in hospital outpatient departments, which typically ends in greater funds. In that state of affairs, Medicare makes a fee to the clinician below the PFS at a charge that’s usually decrease than for freestanding doctor workplaces but in addition makes a separate fee to the hospital below the outpatient potential fee system (OPPS).

Hospital outpatient division (HOPD). Hospital departments that present outpatient providers, resembling clinic visits, injections, and outpatient surgical procedures. There was a big enhance in Medicare spending on HOPD providers over time as care has shifted from inpatient to outpatient settings and as hospitals have acquired doctor practices and immediately employed extra physicians.

Off-campus HOPD. HOPDs that aren’t a part of the hospital campus (i.e., should not bodily near the principle hospital buildings). Off-campus HOPDs typically resemble physicians’ workplaces and will have beforehand been freestanding doctor workplaces that had been acquired by a hospital.

On-campus HOPD. HOPDs which might be a part of the hospital campus (i.e., are a part of or bodily near the principle hospital buildings).

Outpatient potential fee system (OPPS). The fee system that Medicare typically makes use of to cowl hospitals’ prices for HOPD providers, resembling for nursing providers, medical provides, tools, and rooms. OPPS charges range geographically and primarily based on the complexity of the service, amongst different issues. Medicare additionally gives a separate fee to clinicians below the PFS for providers offered in an HOPD.

Doctor payment schedule (PFS). Medicare’s fee system for doctor and different well being care skilled providers. This accounts for clinicians’ labor, apply bills (resembling for lease, tools, and workers), and malpractice insurance coverage. The PFS contains separate charges for facility and nonfacility settings. The PFS charge for providers offered in HOPDs (the speed for facility settings) is often smaller than for providers offered in freestanding doctor workplaces (the speed for nonfacility settings), which displays the truth that HOPDs cowl many bills in any other case incurred by clinicians in freestanding workplaces and are reimbursed for these prices below the OPPS.

This work was supported partially by Arnold Ventures. KFF maintains full editorial management over all of its coverage evaluation, polling, and journalism actions.

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