Site-Neutral Payments

  • Published: July 31, 2024
  • Updated: July 31, 2024

Site neutrality is a defined policy in which Medicare Part B would pay hospital outpatient departments (HOPDs) and physician-based practices the same amount if they provided the same service. While intended to offer patients more transparency and “cut costs” for Medicare, this policy disregards the differences between HOPDs and physician-based practices. This difference is even more pronounced in cancer care, and its potential impact is more severe.

Cancer centers operate large networks to bring care to people where they live and work. These HOPDs often are the only source of specialty cancer care for medically and socially complex patients. This reach into communities is key to ensuring continuity of care for cancer patients whose health is shaped by inadequate transportation, housing, and other social risk factors.

Onerous “site-neutral” payment policies jeopardize access to care by making HOPD expansion into underserved communities financially unsustainable. HOPDs provide essential services like 24/7 service and standby to underserved communities, like those who may be uninsured or on Medicaid. The “site-neutral” payment policy does not acknowledge the complexities of a cancer diagnosis, especially for patients with comorbid chronic conditions or complex cancers beyond the scope of physician-based practices. Due to concerns about costs, those who are under- or uninsured and from lower-income areas get fewer cancer screenings, receive diagnoses at a later stage, and face increased cancer mortality. HOPDs and physician-based practices have different expectations and roles in their communities.

There is much more to a patient cancer journey than simply receiving chemotherapy, radiation therapy, or surgical care. The human experience of patients and families who navigate a cancer journey is frequently made more difficult by patient gaps in health care knowledge, challenges of caring for children, the burden upon the patient’s partner and family, and challenges resulting from nutritional issues or the development of cancer care-related toxicities. Oftentimes, HOPDs are the only site of service where cancer patients and their families may receive appropriate, compassionate mental health treatment and advice.

AACI Position: AACI strongly opposes so-called “site-neutral” payment policies that are, in fact, simply cuts to hospitals. These policies disregard the fundamental differences between the patients cared for in HOPDs and physician offices. As institutions that serve under- and uninsured patients and offer specialized care, HOPDs operate differently than physician-based practices and should be reimbursed accordingly.

As a professional membership association representing over 100 North American academic cancer centers, AACI is concerned about proposals for “site-neutral” payment policies that could result in cuts to HOPDs.

Cancer centers offer specialized expertise in diagnoses and treatment. Cuts to HOPDs could hamper flexibility with newer and emerging therapies. Studies have noted increased survival rates among patients treated at a cancer center as compared to other hospitals and facilities. For example, in the first six months after a breast cancer diagnosis, the cost of treatment for a stage 4 diagnosis is more than double that of breast cancer diagnosed at stage 1. A patient-focused approach, compared against a “site-neutral” payment policy, improves patient outcomes while reducing care costs for families and payors.