Site Neutrality

Background

Medicare pays hospital outpatient departments through the Outpatient Prospective Payment System, which includes a professional fee plus a separate facility fee. Physician offices receive a single consolidated rate through the Medicare Physician Fee Schedule (MPFS), resulting in Medicare paying two to four times more for identical procedures performed in outpatient departments. Site-neutral payment reform would eliminate this differential by reimbursing all settings at the lower MPFS rate, approximately 40% of standard OPPS reimbursement. For echocardiography, this translates to potential 76% cuts on commonly used procedure codes.

Impact on Echocardiography

Echocardiography's diagnostic complexity, involving severe cardiovascular disease, advanced protocols, and time-intensive interpretation, requires significant capital investment in specialized equipment and credentialed personnel that MPFS rates were never designed to support. A 76% cut to commonly used codes would threaten practices' ability to maintain equipment, retain sonographers, and adopt new imaging technologies. Rural hospitals and labs face the greatest risk: total site-neutral cuts to rural hospitals could exceed $1.7 billion in 2026, potentially forcing closures in communities where patients have no alternative site for cardiac imaging.

ASE Recommendations

ASE urges Congress to reject site-neutral payment policies that would harm cardiovascular care by:

• Opposing expansion of site-neutral payment to echocardiography and imaging services
• Ensuring any payment reform accounts for differences in patient acuity, regulatory burden, and infrastructure costs across care settings
• Protecting rural hospitals and labs from cuts that could eliminate access to echocardiography in underserved communities
• Exploring alternative cost-control policies that reduce spending without compromising cardiovascular care quality