Site-neutral payments are a policy proposal that many ASC and physician groups have long supported in an effort to even out payments between ASCs and HOPDs. ASCs historically receive lower reimbursements for the same procedures performed in HOPDs, despite no evidence that care quality is different between the two settings.
Hospitals generally argue in opposition to site neutrality, reasoning that their services cost more to provide and that they face more regulations than other providers.
Here's where industry groups stand on site neutrality:
Oppose:
1. The American Hospital Association. The AHA represents nearly 5,000 hospitals, health systems, networks and other providers. The AHA was part of an effort to establish exceptions for certain off-campus HOPDs that were in construction at the time of the Bipartisan Budget Act of 2015, which enacted site-neutral payments for off-campus HOPDs. They have urged Congress to reject calls from other advocacy groups for additional site-neutral payment policies.
"Instead of considering flawed policies that put patient access to care in jeopardy, Congress should focus on ways to make sure hospitals and health systems have the resources they need to continue providing 24/7 care to all patients in every community," AHA President and CEO Rick Pollack wrote in March.
2. The Federation of American Hospitals. The FAH represents over 1,000 tax-paying community hospitals and health systems.
"FAH and its member hospitals agree with the goal of ensuring patients receive the right care, at the right time, in the right setting," reads a statement on the FAH's website. "However, blunt site-neutral payment policies, such as the current reduction for clinic services performed in hospital provider-based departments ignore fundamental functional and cost structure differences between hospitals and physician offices, among other settings, and the unique, mission-critical services communities rely on hospitals to provide."
3. Center for Medicare Advocacy. CMA is a nonprofit, public-interest law firm advocating for Medicare access and quality. They have opposed site neutrality, specifically citing negative impacts on patients seeking intensive or inpatient rehabilitation services.
"Site-neutral payments would result in patients who need intensive inpatient rehabilitation being diverted inappropriately to less intensive settings based solely on their diagnosis, despite their clinical needs," This is clearly a mistake, and could endanger vulnerable beneficiaries.
4. In May 2023, a number of hospital groups co-signed a letter to the House of Representatives opposing site neutrality, saying it would "negatively impact facilities that provide essential drug administration services for our communities’ most vulnerable patients, many of whom require a higher level of care than may be offered in other health care setting."
Signatories included America's Essential Hospitals, AHA, the Association of American Medical Colleges, the Catholic Health Association of the United States, the Children's Hospital Association, the FAH, the National Association of Behavioral Healthcare, Premier and Vizient.
Support:
5. The American Medical Association. The AMA represents more than 190 state societies and medical specialty associations. The AMA has long stood in support of site neutrality. It supports increasing payment parity without lowering total Medicare payments and believe that payments should be based on the actual costs of providing services. They also say that updated practice expense data is needed and that cost-effective care should be incentivized.
"The AMA does not believe it is possible to sustain a high-quality health care system if site neutrality is defined as shrinking all payments to the lowest amount paid in any setting. Additionally, the AMA urges CMS to pay physicians fairly for office-based procedures and, where clinically appropriate, shift more procedures from the hospital to office setting, which is more cost-effective."
6. American Health Insurance Plans. AHIP represents 1,300 health insurance benefits and services organizations. They advocated for site-neutrality in a May 2022 news release.
"Advance site-neutral payments to defend consumers against having to pay more for the same services depending on the site of care."
7. Blue Cross Blue Shield Association. The BCBSA represents 24 independent BCBS companies.
"[Research] suggests that a site-neutral payment policy could drive substantial cost savings for patients, employers and employees. Site-neutral means you pay the same amount for the same medical service no matter where that service takes place," the organization published on it's website in September 2023.
"To tackle this issue, the Blue Cross Blue Shield Association supports common sense, bipartisan legislation to advance site-neutral policies, including The SITE Act and The FAIR Act. This would save Americans nearly $500 billion over the next decade. Medicare's move to expand site-neutral payments would pave the way for private insurance plans to also implement these payment policies, ultimately increasing access to high-quality and affordable care."
8. Medicare Payment Advisory Commission. MedPAC is an independent federal body that advises Congress on the Medicare program. They vocalized their support for site-neutrality in a June 2023 report to Congress.
"In general, the Commission maintains that Medicare should base payment rates on the resources needed to treat patients in the most efficient setting. If the same service can be safely and appropriately provided in different settings, a prudent purchaser should not pay more for that service in one setting than in another."
9. Ambulatory Surgery Center Association. ASCA represents the interests of more than 5,600 Medicare-certified ASCs nationwide. In March 2023, The ASCA Journal uplifted research in support of making "Medicare a more cost-conscious program that better aligns payment with patient services," with the caveat that it was aware that such policies must be carefully implemented as they "might cause issues of patient access, especially for sicker patients who might require a higher level of service."
10. Other groups who have voiced support for site neutrality include the American College of Physicians, the American Academy of Family Practice, the American Academy of Orthopaedic Surgeons, the American Benefits Council, America's Health Insurance Plans, Amgen, Community Oncology Alliance, Digestive Health Physicians Association, Infusion Providers Alliance, Large Urology Group Practice Association, Men's Health Network, National Brain Tumor Society, The OrthoForum and The US Oncology Network.