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Update: NRHA Hospital Outpatient Proposed Rule Comments

The NRHA submitted its comment letter to CMS this week on its proposed rule outlining changes to the CY 2011 hospital Outpatient Prospective Payment System (OPPS).  Included in the proposal are issues related to the operation of small rural PPS and critical access hospitals which could have a significant impact on the way hospitals operate. Notable provisions of the the NPRM included a proposal to address the hot topic of physician supervision, quality measures for emergency department transfer communications, and a number of provisions required within the Affordable Care Act (health reform). Specifically, the physician supervision proposal, which would slightly change CMS requirements to require direct physician or NPP supervision at the "initiation of service," then allow general supervision for its duration, would not represent a widespread solution to the potential problems rural hospitals have spoken so loudly about on this issue. CMS typically releases final regulations 90 days after a proposed rule's deadline for comments, so we will continue to monitor any updates between now and then. For more information on this and other issues included in the proposed rule, please download the full comment letter here, and contact the NRHA government affairs office with any questions or concerns.

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