The Task Force Provides Input to CMS on CY 2022 OPPS Proposed Rule

The Health Care Transformation Task Force filed comments on the Centers for Medicare and Medicaid Services (CMS) Outpatient Proposed Payment System Proposed Rule (CMS-1753-P).


  1. Proposed Changes to Inpatient Only (IPO) List: The Task Force supports CMS in its proposal to halt the elimination of the IPO, and recommends that CMS create a measured approach to removing services from the IPO List moving forward.
  2. Provision of Mental Health Services: HCTTF urges CMS to retain flexibility that allows Medicare beneficiaries in all geographic areas – not just those in rural areas – to receive telehealth benefits for the provision of mental health services, and that CMS document the volume of telehealth mental health care being provided.
  3. Hospital Outpatient Quality Reporting (OQR) Program: The Task Force comments on several aspects of the OQR, including concerns regarding the proposed use of indirect estimation techniques to increase the volume of race and ethnicity data, as well as support for the use of the Outpatient and Ambulatory Surgery CAHPS measures and the consideration of specific patient-reported outcome measures related to Total Hip Arthroplasty (THA) and Total Knee Arthroplasty (TKA).
  4. Rural Emergency Hospitals RFI:  The Task Force responds to CMS’ RFI with suggestions on how to address the challenges faced by rural and Critical Access Hospitals (CAHs), including 1) implementing a value-based paradigm for maternity care; 2) addressing barriers to access and perinatal workforce shortages in rural areas; and 3) allowing rural hospitals and CAHs more flexibility in how they spend their federal dollars.
  5. Radiation Oncology Model: The Task Force expresses appreciation for the reduction in the discount rates for professional and technical RT providers, but continues to note that these rates will create challenges in the provision of high-value care, given the slim margin in which radiation therapy practices operate. The Task Force also suggests that CMS consider the recommendations in the June 2021 MedPAC Report to Congress regarding the APM portfolio, and how the RO model sits within it.

Read the Letter