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A Voice for Private Physicians Since 1943

Action Alert: Site Neutral Payment

Your help is needed to speak out in support of helpful reforms that will lower costs for patients and protect access to independent physicians!

As a result of harmful Medicare rules, patients often are forced to pay more for certain procedures and medications received at a hospital-owned clinic than they would at an independent physician’s office. 

Two good changes have recently been proposed by the Center for Medicare and Medicaid Services (CMS) to help fix these flaws that not only increase costs for patients but also drive the closure of private practices across the nation.  Comments are needed to show that there is strong support for these reforms that are fiercely opposed by those who unfairly profit from the status quo.

Here are more details:

1) In the 2026 Physician Fee Schedule Proposed Rule, CMS is proposing to adjust its payment formulas in a way that will reduce what it refers to as a “site of service payment differential.”

Comments on the above rule are due by Friday 9/12. Submit a public comment at: https://aapsonline.quorum.us/campaign/140234/  Feel free to modify the template comment if you have time. Additional messaging points are below.

(If you prefer to submit anonymously or upload a document with more extensive comments on #1 please use the CMS comment portal by clicking here.)

2) In the 2026 Hospital Outpatient Proposed Rule, CMS is planning to adjust payment a “site-neutral” way to ensure patients aren’t paying more for the same medications just because they were administered at a hospital facility.

Comments on this “drug administration” proposal are due by Monday 9/15. Submit a public comment on this second proposal at: https://aapsonline.quorum.us/campaign/140230/  Again, feel free to modify or elaborate on the template comment if you have time. Additional messaging points are below.

(If you prefer to submit anonymously or upload a document with more extensive comments on #2 please use the CMS comment portal by clicking here.)

Thank you for speaking out. Your voice makes a difference!


Other Messaging Points to Consider

Economic: Site-neutral payments will save the American taxpayer $150 billion over the next decade if implemented today. That’s an extreme amount of savings for American taxpayers by essentially correcting a billing error.

Patient-focused: Patients should not have to bear the brunt of hospital policies trying to pad bottom lines instead of directing dollars to actual patient care. Common procedures like X-rays and other imaging services cost up to $200-$500 more at a hospital-owned doctor’s office, differences which can have significant financial impacts on patients.

Free-market: Without site-neutrality rules, hospitals will be encouraged to buy up small doctor offices, increasing the reach of the hospital industry and driving up costs of care while lowering its quality. Hospital consolidation can be the difference between a doctor opening their own practice and working for a healthcare conglomerate. Put simply, hospitals will continue to distort the healthcare market if left unchecked without site-neutral payments.

Common sense: Americans should not have to pay more for the same service just because it’s performed in a different building. Prices should be transparent and equal across providers, and site-neutrality ensures that will be possible.

Additional Details: https://paragoninstitute.org/medicare/new-medicare-payment-rules-opps-and-pfs-show-trump-administrations-focus-on-site-neutral-payments-and-reducing-medicares-market-distortions/

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