AAMC Statement on Outpatient Prospective Payment System Final Rule

AAMC (Association of American Medical Colleges) President and CEO Darrell G. Kirch, MD, issued the following statement regarding the 2019 Medicare Outpatient Prospective Payment and Ambulatory Payment Systems (OPPS) final rule released today by the Centers for Medicare and Medicaid Services (CMS):

“The AAMC is extremely disappointed that CMS exceeded its regulatory authority and ignored feedback from a bipartisan group of nearly 200 members of Congress and stakeholder opposition by finalizing the expansion of flawed site-neutral payment policies. This is a reduction of 60% in Medicare reimbursements to excepted off-campus provider-based departments. The two-year phase-in included in the final rule still threatens access to care for Medicare beneficiaries and disproportionately harms low-income, vulnerable patients and the institutions that serve them. By finalizing proposals to cut reimbursements to excepted off-campus provider-based departments, CMS disregards congressional intent. Consequently, the AAMC, joined by the American Hospital Association and member hospitals, will promptly bring a court challenge to the new rule’s site-neutral provisions. 

CMS asserts that increases in outpatient care over the last few years are ‘unnecessary.’ In fact, the increases are the result of a combination of several factors, including clinical advances, growth in the population covered by Medicare, and policy changes CMS has made to drive the delivery of health care services to lower-cost outpatient settings. We do appreciate that CMS accepted some of the AAMC’s recommendations and did not finalize the proposal to create families of services that would have further limited beneficiaries’ access to care.

Teaching hospitals’ off-campus outpatient departments treat vulnerable patients who often can only find care at these institutions. These sites differ substantially from traditional physician offices in the types of patients treated, services provided, and amount of administrative and regulatory burden required. More than half of patients treated at off-campus outpatient departments require higher levels of care than those treated in physicians’ offices. Extending cuts to these departments will limit the ability of these patients to access the care they need.”


The Association of American Medical Colleges is a not-for-profit association dedicated to transforming health care through innovative medical education, cutting-edge patient care, and groundbreaking medical research. Its members are all 152 accredited U.S. and 17 accredited Canadian medical schools; nearly 400 major teaching hospitals and health systems, including 51 Department of Veterans Affairs medical centers; and more than 80 academic societies. Through these institutions and organizations, the AAMC serves the leaders of America’s medical schools and teaching hospitals and their more than 173,000 full-time faculty members, 89,000 medical students, 129,000 resident physicians, and more than 60,000 graduate students and postdoctoral researchers in the biomedical sciences.