Reject Site Neutral Payments

The Issue

Site neutral payments refers to proposals that would eliminate the differential pricing between a hospital or hospital outpatient department and a freestanding clinic.  In recent years, Congress and the Administration have looked to implement site neutral payments as way to reduce Medicare spending at hospital outpatient departments, which are reimbursed at a higher rate than a freestanding clinic.  By implementing so-called site neutral payments, these proposals would instead reimburse hospital-based outpatient departments, such as the Foster Family Community health Center, at a significantly reduced rate.

The Impact

Munson Healthcare currently operates 49 off-campus Hospital Outpatient Departments in 29 communities of Northern Michigan.  This includes providing services such as radiology and lab services at rural and remote locations throughout our 11,000 square mile service area.

Munson Medical Center in Traverse City is our largest hospital and operates several off-campus hospital-based departments that provide critical services such as cardiac rehab, childbirth services, behavioral health and infusion services and cancer care.  For Munson Medical Center, over 8.5% of our total payments are for services provided in an excepted off-campus location including:  

  • Advanced Wound Center
  • Audiology Hearing Clinic
  • Sleep Disorders Center
  • Bay Area Urology
  • Munson Community Health Center
  • Munson Nephrology Consultants
  • Smith Family Breast Health Center
  • Thomas Judd Center

At these locations, services provided include:

  • General surgery
  • Physical Therapy
  • Radiology
  • Oncology/Infusion
  • X-Ray
  • Cardiac Rehab
  • Childbirth Services
  • Community Health
  • EMS Education
  • Healthy Weight Center
  • Home Health / Hospice
  • Massage Therapy
  • Nutrition
  • Occupational Health
  • Pain Management
  • Pharmacy
  • Pre-Procedure Services
  • Pulmonary Rehab
  • Sleep Center
  • Urgent Care

These services would not be provided by any physician’s office or freestanding clinic and are only being provided because of Munson Healthcare’s commitment to providing the highest quality of care, closest to home for the patients we serve.

If site neutral payments were extended to currently excepted facilities, we risk the continued operation of specific service line such as:

  • Behavioral Health Services including Psych and Substance Abuse
  • Women’s and Children’s services including Pediatrics and O/B care. 
  • Specialty Care Services including Neonatology, Nephrology, Infectious Disease, HIV and Bariatric services
  • Cancer Care including Infusion services

What You Can Do

Consider reaching out to your member of Congress and Senators to ask them to ensure no further site neutral reductions for hospitals or outpatient departments.

  • Please support passage of H.R. 2552 the Protecting Local Access to Care for Everyone Act
    • This legislation would prevent the full impact of harmful payment reductions for clinic visits at off-campus provider based departments.
    • These reductions were the result of the CMS CY19 Outpatient Prospective Payment System Rule
    • The impact on Munson Healthcare is a reduction of almost $1 million dollars for clinic visits, primarily at our outpatient pain clinic at Munson Community Health Center.
  • Please ensure that site neutral payments are not used to offset a debit limit increase or budget agreement
    • Site neutral payments were included in the 2015 Bipartisan Budget Act as a fiscal offset