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ACCC Comments on 2021 Proposed OPPS and PFS Rules

October 14, 2020

By Christian G. Downs, MHA, JD

On Oct. 5, ACCC provided comments to the Centers for Medicare & Medicaid Services (CMS) on the agency’s proposed CY 2021 Outpatient Prospective Payment System (OPPS) and Physician Fee Schedule (PFS) rules. CMS is expected to release the final CY 2020 Medicare payment rules in early December. Below are highlights from ACCC’s comment letters.

Specific to the proposed OPPS Rule, ACCC recommends that CMS:

  • Not finalize its proposal to further reduce the payment rate for separately payable drugs acquired under the 340B Program to protect rural and underserved providers and beneficiaries. ACCC believes that the proposal to further reduce payment for 340B drugs fails to account for the numerous harmful effects it will have on patient access to care. Instead, ACCC urges CMS to continue its current policy of paying ASP minus 22.5 percent for 340B drugs.


  • Finalize its proposed changes in the level of supervision of NSEDTS (non‐surgical extended duration services) as long as hospitals retain the flexibility to determine how best to staff these services, both with respect to the individuals who may be providing the services and how the hospital chooses to meet the supervision requirements.


  • Reverse, not extend, its requirement for prior authorization for certain outpatient department services. ACCC member institutions continue to experience increases in unnecessary and burdensome prior authorization, delaying patient care and increasing the administrative burden on hospitals. To protect patients, CMS should reverse its prior authorization policies finalized last year instead of extending them to additional service categories.

In its letter, ACCC supports the proposal regarding changes in the level of supervision of outpatient therapeutic services in hospitals and critical access hospitals, but it seeks clarification on how that supervision will apply to chemotherapy and radiation oncology.

Specific to the proposed PFS Rule, ACCC recommends that CMS:

  • Mitigate the detrimental impact of increased payment for office/outpatient E/M (evaluation and management) visits, which have been offset by reductions to surgery and radiology oncology services, among others, by seeking a balanced approach to payment for all services. ACCC is deeply concerned about the impact of offset reductions on radiation oncology and surgery. The agency’s own CY 2021 financial impact analysis of changes in the rule predicts a 6 percent decrease in Medicare PFS payments for radiation oncology and radiation treatment centers, and an 11 percent decrease for radiology. All surgical specialties included in this analysis would also face a decrease in total allowed charges if CMS’s proposals are implemented.


  • Not finalize its proposal to assign certain section 505(b)(2) drug products to multiple source drug codes for purposes of Part B payment, which would not lower prices for providers and would create uncertainty about reimbursement rates.


  • Finalize its proposal to increase flexibilities for telehealth services and CTBS (communication technology-based services), which expand access to services for patients in need. Specifically, ACCC supports CMS’s proposals to allow the specific CTBS codes to be billed by licensed clinical social workers and clinical psychologists, as well as physical therapists, occupational therapists, and speech-language pathologists, who bill Medicare directly for their services. In addition, ACCC supports CMS’s proposals to adopt two new G codes for the remote evaluation of downloadable images/recorded video and for virtual check-ins that would allow certain non-physician practitioners who cannot independently bill for E/M services to bill for these services.

Read the full text of ACCC’s comment letters to CMS on the agency’s proposed CY 2021 Physician Fee Schedule and Outpatient Prospective Payment System rules.

Christian G. Downs, MHA, JD, is the Executive Director of the Association of Community Cancer Centers.




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