The Task Force Provides Input to CMS on CY 2023 OPPS/ASC Proposed Rule

The Health Care Transformation Task Force submitted comments on the CY 2023 Centers for Medicare and Medicaid Services (CMS) Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Proposed Rule (CMS-1772-P). The Task Force letter focused on the following:

  1. Inpatient Only List (IPO): HCTTF supports CMS’ criteria for removing services from the inpatient only list (IPO) but urges CMS to proactively monitor how changes in site-of-service may affect participants in alternative payment models.
  2. Changes Related to Behavioral Health Services:
    • The Task Force supports allowing hospital outpatient staff to be reimbursed for delivery of mental health services furnished to patients remotely. At the same time, the Task Force opposes the criteria to require hospital staff to be eligible for reimbursement only when the staff person is providing those services from an outpatient hospital setting.
    • The Task Force supports CMS’ proposal to allow for audio-only telehealth services if the individual patient’s technological limitations, abilities, or preferences request it.  At the same time, the Task Force recommends CMS collect data on the reason why a patient declines to participate in video telehealth services, to support ongoing understanding of this field of delivery and to inform future policy decisions.
  3. Overall Hospital Quality Star Rating: The Task Force continues to support including Veterans Health Administration hospitals in the star rating calculation, and also supports CMS’ proposal to refresh the Hospital Compare measure results in a more timely manner.


Read the Letter