The Alliance submitted comments to CMS in response to its proposed CY 2019 Hospital Outpatient Prospective Payment System (PPS) and Ambulatory Surgical Center Payment Systems as well as changes to the Quality Reporting Programs. The Alliance focused its comments on provisions related to:

• CTP packaging and payment methodology
• Pass through status for CTPs
• Guidelines
• Methods to control unnecessary increases in the volume of outpatient services
• Ways to control unnecessary costs
• Price transparency

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