Is Site-Neutral Medicare Payment Policy Really Beneficial or Flawed?

February 12, 2025

The issue of site-neutral payment policies is a hotly debated topic among lawmakers in Washington. This proposed legislation seeks to revolutionize the way Medicare reimburses healthcare providers by mandating the same payment rates for specific services, regardless of whether they are performed in physician offices, ambulatory surgery centers (ASCs), hospital outpatient departments, or other provider settings. Richard Fogel, the chief health outcomes officer at Ascension, one of the country’s largest nonprofit and Catholic health systems, has voiced significant concerns about this policy, highlighting its potential negative impacts and underlying flaws.

The Concept of Site-Neutrality

The concept of site-neutrality is based on the principle that a medical service should carry the same cost regardless of the setting it is performed in. Under this proposal, Medicare would reimburse the service at the lowest cost observed across different settings. This approach is touted as a fair and cost-saving measure for the Medicare system. However, Fogel emphasizes that this methodology is fundamentally flawed because it overlooks the diverse clinical needs of patients and the varied capabilities of different healthcare settings.

One of Fogel’s primary arguments is that patients have unique treatment requirements which can vary significantly based on their individual health conditions. For example, a routine medical procedure such as a colonoscopy might be straightforward and safe for a healthy individual when done in an ASC, but the same procedure becomes far more complex and riskier for a patient with multiple severe chronic conditions, necessitating the resources and personnel available at a hospital outpatient department. Applying a uniform reimbursement rate ignores these complexities and the associated higher risks, which can compromise patient safety and care quality.

Moreover, the push for site-neutral payments fails to account for the inherent differences between various healthcare settings. Unlike ASCs or physician offices, hospitals are structured to handle a wide range of complex care needs. They are equipped with substantial resources to provide round-the-clock services, including emergency and critical care, which are indispensable for uninsured and underinsured patients. Hospitals also support comprehensive services that smaller, independent providers cannot, including lifesaving trauma care and advanced diagnostic and therapeutic procedures. The higher reimbursements for hospitals are not arbitrary but crucial for maintaining their capability to deliver these essential services to diverse and vulnerable patient populations.

The Role of Hospitals in Complex Care

Hospitals are uniquely positioned to manage intricate and varied healthcare needs. These institutions invest in significant resources to offer continuous services, particularly emergency and critical care, which are essential for uninsured and underinsured patients who may not otherwise have access to necessary medical attention. Hospitals additionally provide a wide range of services that smaller independent providers often do not, such as specialized trauma care and advanced diagnostic procedures. Thus, the higher reimbursements for hospitals are integral to sustaining their capacity to address a broad array of patient requirements, including those of the most vulnerable individuals.

The potential consequences of adopting site-neutral payment policies extend well beyond individual patient care. According to Fogel, if such policies are put into place, hospitals across the nation could experience severe financial strain. This strain could lead to service cutbacks or even closures, with particularly dire effects on rural hospitals where alternative care settings such as ASCs or specialty clinics are scarce. Patients in rural communities depend exclusively on their local hospitals for a comprehensive range of medical services. If these hospitals are compelled to operate under a reimbursement model that does not reflect the true costs of care, their ability to function effectively and sustainably is at high risk.

Financial Implications and Risks

Fogel argues that instead of enforcing a one-size-fits-all payment model, healthcare reimbursement policies should recognize the diverse needs of patients and the different capabilities of healthcare providers. Each site of service, whether it is a hospital or an outpatient center, has its own strengths and operational costs, which should be considered in the payment structure. Overlooking these differences not only oversimplifies the healthcare payment system but also endangers the quality and accessibility of patient care.

The proposals for site-neutral payments appear attractive to policymakers and special interest groups because they purport to offer fairness and fiscal savings for Medicare. However, Fogel cautions that these proposals divert attention from the deeper, more fundamental issues that contribute to high healthcare costs in the United States. Furthermore, these policies do not ensure that patients receive care in the most clinically appropriate settings, potentially leading to suboptimal care or even harm for many patients.

The overarching consensus from Fogel’s perspective is that while site-neutral payments might seem equitable on the surface, they are inherently flawed. These policies fail to acknowledge the nuanced and credible distinctions in patient care needs and the capabilities of different healthcare providers. As a result, their implementation could undermine patient access to necessary and appropriate care, especially for the most complex and vulnerable patient populations.

The Need for a Nuanced Approach

The issue of site-neutral payment policies is currently a highly contentious topic among lawmakers in Washington. This proposed legislation aims to transform the way Medicare reimburses healthcare providers by requiring identical payment rates for certain services, no matter if they are conducted in physician offices, ambulatory surgery centers (ASCs), hospital outpatient departments, or other healthcare settings. Richard Fogel, who serves as the chief health outcomes officer at Ascension—one of the largest nonprofit and Catholic health systems in the country—has expressed major concerns regarding this policy. He points out that it carries the potential for considerable negative impacts and exhibits significant underlying flaws. Fogel argues that by enforcing uniform payment rates, this policy fails to consider the varying costs and resources associated with different healthcare settings, potentially compromising the quality of care and accessibility for patients. As debate continues, it highlights the complexity of balancing cost control with maintaining high standards in healthcare delivery.

Subscribe to our weekly news digest.

Join now and become a part of our fast-growing community.

Invalid Email Address
Thanks for Subscribing!
We'll be sending you our best soon!
Something went wrong, please try again later