Resource Library: Results | Outpatient Facility Fee Reform: A 50-State Review

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The Harmful Impact of “Site-Neutral” Policies on Community Hospitals

Authors: FTI Consulting
Date: 2/1/2026
Resource Type: Gray literature
The brief argues that expanding Medicare site-neutral payment policies would cut hospital outpatient payments by billions and threaten access to care because hospitals face unique costs and financial pressures.
Details
Publisher/Organization: FTI Consulting
Payer: Medicare
Summary: The brief analyzes the potential impact on community hospitals of applying site-neutral payment policies to 57 ambulatory payment classifications that MedPAC’s 2023 report identified as safe and routinely provided in physician offices or ambulatory surgical centers. Authors report that site-neutral reforms could reduce Medicare payments to hospitals by about $182 billion over ten years, including $26.3 billion to rural hospitals. Many hospitals could face financial distress and cuts may disproportionately affect emergency, maternal, and mental health service lines. The report notes that hospitals already operate under significant financial and workforce challenges, and further payment reductions could impair hospitals’ ability to sustain access to essential services in vulnerable communities.
Funding Disclosure: The Coalition to Strengthen America’s Healthcare provided funding for this work.
Topic Areas: Site-Neutrality, Patients & Quality, Policy Reforms
Citation: FTI Consulting. The Harmful Impact of “Site‑Neutral” Policies on Community Hospitals. Coalition to Strengthen America’s Healthcare; February 2026. https://strengthenhealthcare.org/wp-content/uploads/2026/02/Medicare_Site-Neutral_2026.2.04-1.pdf.

Comparison of Care in Hospital Outpatient Departments and Independent Physician Offices 2019-2024

Authors: KNG Health Consulting LLC
Date: 9/1/2025
Resource Type: Web content
The analysis finds that Medicare patients treated in hospital outpatient departments are more medically complex and socioeconomically vulnerable than those in independent physician offices.
Details
Publisher/Organization: KNG Health Consulting
Payer: Medicare
Summary: Using Medicare claims data from 2019 to 2024, the authors compare patients treated in hospital outpatient departments (HOPDs) and independent physician offices. The analysis finds that HOPD patients are more likely to be under 65 and disabled, dually eligible for Medicare and Medicaid, from lower-income and rural areas, and have more severe chronic conditions and higher prior use of hospital and emergency services. These differences suggest that HOPDs treat a sicker, higher-need population, which may justify higher payments in these settings.
Funding Disclosure: The American Hospital Association provided funding for this work.
Topic Areas: Patients & Quality
Citation: KNG Health Consulting LLC; Comparison of Care in Hospital Outpatient Departments and Independent Physician Offices: Updated Findings for 2019‑2024. American Hospital Association; September 2025. https://www.aha.org/comparison-care-hospital-outpatient-departments-and-independent-physician-offices

Comparison of Care in Hospital Outpatient Departments and Independent Physician Offices Among Cancer Patients

Authors: KNG Health Consulting LLC
Date: 9/1/2025
Resource Type: Web content
The analysis finds that Medicare patients with cancer who are treated in hospital outpatient departments are more medically complex and socioeconomically vulnerable than those in physician offices.
Details
Publisher/Organization: KNG Health Consulting
Payer: Medicare
Summary: Using Medicare claims data from 2019 to 2024, authors compared the characteristics of patients with cancer receiving care in hospital outpatient departments (HOPDs) to patients in independent physician offices. The analysis finds that patients treated in HOPDs are more likely to be under age 65 and disabled, dually eligible for Medicare and Medicaid, from lower-income or rural communities, and have more severe chronic conditions and higher prior use of hospital and emergency services. These findings indicate that differences in patient mix and complexity may help explain why care in hospitals is often more expensive.
Funding Disclosure: The American Hospital Association provided funding for this work.
Topic Areas: Patients & Quality
Citation: KNG Health Consulting LLC. Comparison of Care in Hospital Outpatient Departments and Independent Physician Offices Among Cancer Patients: Updated Findings for 2019–2024. American Hospital Association; September 2025. https://www.aha.org/comparison-care-hospital-outpatient-departments-and-independent-physician-offices-among-cancer-patients-updated-findings-2019.

Are Hospital Acquisitions of Physician Practices Anticompetitive?

Authors: Zack Cooper, Stuart V Craig, Aristotelis Epanomeritakis, Matthew Grennan, Joseph R Martinez, Fiona Scott Morton and Ashley T Swanson
Date: 7/1/2025
Resource Type: Gray literature
The study reviews claims and merger data and shows that hospital-physician integration has increased by 71.5% between 2008 and 2016, and integration has raised labor and delivery costs.
Details
Publisher/Organization: Yale Tobin Center for Economic Policy
Payer: Commercial Insurance
Summary: The study looks at hospital merger data and commercial claims data for labor and delivery from 2011-2016. In the two years after integration, hospital prices for labor and delivery increased on average by 3.3% ($475), while physician prices rose by 15.1% ($502). The researchers find no significant improvements in quality that might justify the price increases, In fact, they observed an increase of 4.5-8.0% in cesarean section rates, which are often considered a sign of physician-induced demand rather than improved care. Across specialties, the share of physicians integrated with a hospital also increased by 71.5% from 2008 to 2016.
Funding Disclosure: Arnold Ventures and the Commonwealth Fund provided funding for this work.
Topic Areas: Vertical Integration, Patients & Quality
Citation: Cooper Z, Craig SV, Epanomeritakis A, Grennan M, Martinez JR, Scott Morton F, Swanson A. Are Hospital Acquisitions of Physician Practices Anticompetitive? NBER Working Paper No. 34039. National Bureau of Economic Research; July 2025. doi:10.3386/w34039. https://www.nber.org/papers/w34039

Potential US Health Care Savings Based on Clinician Views of Feasible Site-of-Care Shifts

Authors: Nikhil R Sahni, Crosbie Marine, David M Cutler, Laura N Medford-Davis, Melvin Mezue, Omar Kattan, Ed Levine, Karen E Joynt Maddox
Date: 8/1/2024
Resource Type: Peer-reviewed article
Based on clinician surveys and claims data, the study finds that about 10% of hospital services that Medicare and commercial patients receive could safely shift to lower-cost sites and lead to substantial savings.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance, Medicare
Summary: This survey study of 1,069 clinicians in 2021, combined with 2019 claims data, assesses how much care delivered in hospital settings could be shifted to lower-cost care sites without compromising clinical outcomes. Respondents evaluated more than 300 care activities and indicated that about 10.3% of commercial care volume and 10.9% of Medicare volume in hospital settings could safely occur elsewhere. Based on 2019 reimbursement rates, shifting this care would be associated with annual savings of approximately $113.8 billion to $147.7 billion for the overall health care system.
Funding Disclosure: The Agency for Healthcare Research and Quality provided funding for this work.
Topic Areas: Payment Differentials, Patients & Quality
Citation: Sahni NR, Marine C, Cutler DM, et al. Potential US Health Care Savings Based on Clinician Views of Feasible Site-of-Care Shifts. JAMA Netw Open. 2024;7(8):e2426857. August 1, 2024. doi:10.1001/jamanetworkopen.2024.26857

Prices and Complications in Hospital-Based and Freestanding Surgery Centers

Authors: James C Robinson, Christopher M Whaley, and Sanket S Dhruva
Date: 4/1/2024
Resource Type: Peer-reviewed article
The study finds the prices commercial Blue Cross Blue Shield plans paid for colonoscopies, arthroscopies, and cataract removal were 44-55% higher when hospital outpatient departments provided the service than ambulatory surgery centers.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: This study analyzes the volume and prices of colonoscopy, knee or shoulder arthroscopy, and cataract removal in hospital outpatient departments (HOPDs) and ambulatory surgery centers (ASCs). Using national commercial claims data from Blue Cross Blue Shield insurance plans in 2019-2020, the researchers find the average volume of the procedures were 44-134% higher in ASCs compared to HOPDs. Additionally, prices paid for the services in HOPDs were 44-55% higher than in ASCs. Complications within 90 days of the procedures were more common for procedures in HOPDs for colonoscopy and similar across settings for arthroscopy and cataract removal.
Funding Disclosure: The National Institute for Health Care Management provided funding for this work.
Topic Areas: Payment Differentials, Patients & Quality
Citation: Robinson JC, Whaley CM, Dhruva SS. Prices and complications in hospital-based and freestanding surgery centers. Am J Manag Care. 2024;30(4):179-184. doi:10.37765/ajmc.2024.89529.

Review of Expert and Academic Literature Assessing the Status and Impact of Site-Neutral Payment Policies in the Medicare Program

Authors: Zack Cooper, Elizabeth Jurinka, and Daniel Stern
Date: 10/1/2023
Resource Type: Gray literature
The literature review finds that payment differences across settings raises Medicare and commercial insurance spending, encourage hospital-physician integration, and lack evidence of better quality care in higher-paid hospital outpatient settings.
Details
Publisher/Organization: Yale Tobin Center for Economic Policy
Payer: Medicare
Summary: The review synthesizes literature on Medicare’s site-neutral payment policies. It shows that payment differences for the same outpatient services across hospitals, ambulatory surgical centers, and physician offices increase spending and beneficiary costs. Eliminating these differences could lower costs without harming quality. The authors find that payment differentials have encouraged hospital-physician vertical integration, but peer-reviewed evidence has shown that hospital-based care does not yield better patient outcomes for comparable services. Because commercial payers often follow Medicare’s lead, these payment disparities extend into the commercial insurance market. The review also discusses site-neutral policies and proposals as of 2023.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Payment Differentials, Vertical Integration, Policy Reforms, Site-Neutrality, Patients & Quality
Citation: Cooper Z, Jurinka E, Stern D. Review of Expert and Academic Literature Assessing the Status and Impact of Site-Neutral Payment Policies in the Medicare Program. Yale Tobin Center for Economic Policy; October 30, 2023. https://tobin.yale.edu/sites/default/files/2023-10/Site-Neutral%20Payment%20Literature%20Review%2010302023.pdf.

Comparison of Medicare Beneficiary Characteristics Between Hospital Outpatient Departments and Other Ambulatory Care Settings

Authors: Lane Koenig, Julia Sheriff, Ori Nevo, and Mehmet Sari
Date: 3/1/2023
Resource Type: Gray literature
The report shows that Medicare patients treated in hospital outpatient departments are more medically complex and socioeconomically vulnerable than those in independent physician offices or ambulatory surgical centers.
Details
Publisher/Organization: KNG Health Consulting
Payer: Medicare
Summary: Using a five percent sample of Medicare fee-for-service claims from 2019-2021, the report finds that beneficiaries treated in hospital outpatient departments (HOPDs) have substantially different characteristics than those seen in independent physician offices or ambulatory surgical centers (ASCs). HOPD patients are more likely to be dually eligible for Medicare and Medicaid, have lower incomes, identify as non-white race/ethnicity, qualify for Medicare due to disability or end-stage renal disease, and have higher clinical complexity and prior hospital and emergency department utilization. The authors observe similar patterns when comparing HOPDs to ASCs, indicating that HOPDs serve sicker and higher-need populations. These differences in patient mix and complexity suggest that care costs and resource requirements vary by setting.
Funding Disclosure: The American Hospital Association provided funding for this work.
Topic Areas: Patients & Quality
Citation: Koenig L, Sheriff J, Nevo O, and Sari M. Comparison of Medicare Beneficiary Characteristics Between Hospital Outpatient Departments and Other Ambulatory Care Settings. American Hospital Association; March 22, 2023. https://www.aha.org/system/files/media/file/2023/03/Comparison-of-Medicare-Beneficiary-Characteristics-Between-Hospital-Outpatient-Departments-and-Other-Ambulatory-Care-Settings.pdf

June 2022 Report: Aligning Fee-for-Service Payment Rates Across Ambulatory Settings

Authors: Medicare Payment Advisory Commission
Date: 6/1/2022
Resource Type: Government Report
The government report identifies outpatient services where Medicare could adopt site-neutral payments across care settings.
Details
Publisher/Organization: MedPAC
Payer: Medicare
Summary: The analysis evaluates Medicare’s Outpatient Prospective Payment System (OPPS) and identifies opportunities for site-neutral payment across ambulatory payment classifications (APCs). It finds that for 57 APCs, it would be reasonable to align payments across hospital outpatient departments (HOPDs), ambulatory surgery centers (ASCs), and physician offices at the physician fee schedule (PFS) rate; for eleven APCs, HOPD and ASC payments could be aligned to ASC rates while physician offices remain at PFS levels; and for 101 APCs, differential payments are likely appropriate because HOPDs are the most suitable setting. While acknowledging that HOPDs incur higher costs due to requirements such as maintaining standby emergency capacity, the authors find little evidence that patients receiving the services examined are systematically more complex or sicker in hospital settings. They suggest that higher-acuity services—such as emergency department, critical care, and trauma visits—may warrant distinct payment categories.
Funding Disclosure: N/A
Topic Areas: Site-Neutrality, Patients & Quality, Policy Reforms
Citation: Medicare Payment Advisory Commission. Report to the Congress: Medicare and the Health Care Delivery System — June 2022, Chapter 6: Aligning Fee-for-Service Payment Rates Across Ambulatory Settings. Washington, DC: MedPAC; June 2022. https://www.medpac.gov/wp-content/uploads/2022/06/Jun22_Ch6_MedPAC_Report_to_Congress_SEC.pdf

Site‐Based Payment Differentials for Ambulatory Services Among Individuals with Commercial Insurance

Authors: Aditi P Sen, Yashaswini Singh, and Gerard F Anderson
Date: 2/1/2022
Resource Type: Peer-reviewed article
The study finds that commercial payments for outpatient services were 145% higher in hospital outpatient departments than physician offices in 2018, and out-of-pocket spending was 109% higher.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: This study analyzes 2018 commercial claims data to compare payments for outpatient services across sites of care. It finds that total payments, including facility and professional fees, were on average 145% higher in hospital outpatient departments (HOPDs) than in physician offices. Price differences between settings were highest for pathology and laboratory services. It also finds that patient out-of-pocket spending was 109% higher in HOPDs. Additionally, patients treated in HOPDs had higher risk scores and received more same-day services. However, it is unclear whether this reflects true differences in patient complexity or coding practices.
Funding Disclosure: Arnold Ventures provided funding for this work.
Topic Areas: Payment Differentials, Patients & Quality
Citation: Sen AP, Singh Y, Anderson GF. Site-based payment differentials for ambulatory services among individuals with commercial insurance. Health Serv Res. 2022;57(5):1165-1174. doi:10.1111/1475-6773.13935.

Weighing the Effects of Vertical Integration Versus Market Concentration on Hospital Quality

Authors: Marah N Short and Vivian Ho
Date: 2/1/2019
Resource Type: Peer-reviewed article
The study finds that hospital-physician vertical integration has limited effects on quality, while greater hospital market concentration is associated with worse patient satisfaction.
Details
Publisher/Organization: N/A
Payer: N/A
Summary: By analyzing 29 hospital quality measures from the Centers for Medicare & Medicaid Services Hospital Compare data from 2008 to 2015, the study assesses the effects of vertical integration and market concentration on quality of care. It finds that integration between hospitals and physicians has limited or no consistent impact on most quality measures. In contrast, greater hospital market concentration is associated with declines in all ten patient satisfaction measures.
Funding Disclosure: The Agency for Healthcare Research and Quality provided funding for this work.
Topic Areas: Vertical Integration, Patients & Quality
Citation: Short MN, Ho V. Weighing the Effects of Vertical Integration Versus Market Concentration on Hospital Quality. Med Care Res Rev. 2020 Dec;77(6):538-548. doi:10.1177/1077558719828938.
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