/ en Fri, 25 Apr 2025 14:48:13 -0500 Thu, 27 Mar 25 13:13:34 -0500 /lettercomment/2025-03-27-senate-letter-aha-other-organizations-support-conrad-state-30-and-physician-access-reauthorization-act <div class="container"><div class="row"><div class="col-md-8"><p>March 26, 2025</p><div class="row"><div class="col-md-6"><p>The Honorable David Valadao<br>US House of Representatives<br>2465 Rayburn House Office Building<br>Washington D.C., 20515</p></div><div class="col-md-6"><p>The Honorable Brad Schneider<br>US House of Representatives<br>300 Cannon House Office Building<br>Washington D.C., 20515</p></div></div><div class="row"><div class="col-md-6"><p>The Honorable Don Bacon<br>US House of Representatives<br>2104 Rayburn House Office Building<br>Washington D.C., 20515</p></div><div class="col-md-6"><p>The Honorable Sylvia Garcia<br>US House of Representatives<br>2419 Rayburn House Office Building<br>Washington D.C., 20515</p></div></div></div><div class="col-md-4"><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/03/senate-letter-from-aha-other-organizations-in-support-of-conrad-state-30-and-physician-access-reauthorization-act-s709-3-26-2025.pdf" target="_blank">Download the Senate Letter PDF</a></div><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/lettercomment/2025-03-27-house-letter-aha-other-organizations-support-conrad-state-30-and-physician-access-reauthorization-act" target="_blank">Read the House Letter</a></div></div></div><div class="row"><div class="col-md-8"><p>Dear Senators Klobuchar, Collins, Rosen, and Tillis:</p><p>On behalf of the 45 undersigned organizations, we are writing to strongly support the introduction of the Conrad State 30 and Physician Access Reauthorization Act (S. 709).</p><p>The healthcare workforce is under increasing strain. The aging U.S. population is increasing demand for healthcare services while also contributing to physician attrition. At the same time, reimbursement challenges in Medicare, along with insufficient investment in graduate medical education, have made the practice of medicine more difficult and constrained the pipeline of new doctors. These challenges are particularly acute in rural and underserved communities, where workforce shortages have led to severe access issues. Today, more than 80 million Americans lack adequate access to primary care, exacerbating health disparities across the country.</p><p>Confronting this challenge will require a comprehensive approach from Congress. A key part of the solution is leveraging international medical graduates (IMGs). One in five physicians in the U.S. is foreign-born, and these doctors play an essential role in filling workforce shortages in areas and specialties that struggle to recruit and retain physicians. These include geriatric medicine, interventional cardiology, nephrology, neurology, and critical care medicine, where IMGs are disproportionately represented. The Conrad 30 program is an effective tool for incentivizing U.S.-trained international physicians to work in these high-need areas.</p><p>Over the last 30 years, the program has facilitated placement of approximately 20,000 physicians in communities that otherwise might not have had access to health care. The program has also demonstrated success at retaining physicians beyond the three-year commitment. However, misaligned incentives and outdated policies are jeopardizing the future success of the program.</p><p>The Conrad State 30 and Physician Access Reauthorization Act would make necessary updates to strengthen the program. In addition to gradually increasing the number of available waivers per state if certain thresholds are met, it also clarifies and improves the waiver process for both physicians and employers by making clear the transition period between receiving a waiver and beginning work. These commonsense changes will improve program efficiency and help ensure that more IMGs can pursue opportunities in underserved areas.</p><p>One of the strengths of the Conrad 30 program is its flexible design, which allows each state to tailor the program to meet its specific healthcare needs. This reauthorization will reinforce that flexibility while providing needed clarity and incentives to attract and retain more highly qualified physicians. As workforce shortages worsen, Congress must act with urgency to advance this legislation and strengthen one of the most successful programs for addressing healthcare workforce shortages.</p><p>Thank you again for your leadership on this important issue. We look forward to working with you to advance this bill and ensure that the Conrad 30 program continues to serve as a healthcare and economic lifeline for communities in need.</p><p>Sincerely,</p><p>Alliance for Headache Disorders Advocacy<br>Ambulatory Surgery Center Association<br>American Academy of Family Physicians<br>American Academy of Neurology<br>American Academy of Physical Medicine and Rehabilitation<br>American Association of Child and Adolescent Psychiatry<br>American Association of Neuromuscular & Electrodiagnostic Medicine<br>American Brain Coalition<br>American College of Obstetricians and Gynecologists<br>American College of Physicians<br>American College of Radiology<br>American College of Rheumatology<br>American College of Surgeons<br>American Gastroenterological Association<br>American Geriatrics Society<br>黑料正能量 Association<br>American Medical Association<br>American Psychiatric Association<br>American Society of Anesthesiologists<br>American Society of Neuroradiology<br>Anxiety and Depression Association of America<br>Association for Advancing Physician and Provider Recruitment (AAPPR)<br>Association of Clinicians for the Underserved (ACU)<br>Association of American Medical Colleges<br>Association of University Professors of Neurology<br>College of American Pathologists<br>Bobby Jones Chiari & Syringomyelia Foundation<br>Dystonia Medical Research Foundation<br>Federation of 黑料正能量s (FAH)<br>Hope for HIE<br>Hydrocephalus Association<br>Infectious Diseases Society of America<br>International Bipolar Foundation<br>M-CM Network<br>Miles for Migraine<br>MLD Foundation<br>NANOS (North American Neuro- opthalmology Society)<br>National Ataxia Foundation<br>The Niskanen Center<br>Phelan-McDermid Syndrome Foundation<br>Physicians for American Healthcare Access (PAHA)<br>Premier Inc.<br>Society of Hospital Medicine<br>The Society of Thoracic Surgeons<br>SynGAP Research Fund dba CURE SYNGAP1<br> </p></div></div></div> Thu, 27 Mar 2025 13:13:34 -0500 Physician Self-Referral Law/Stark law /lettercomment/2025-03-27-aha-letter-opposing-physician-led-and-rural-access-quality-care-act-hr2191 <p>March 25, 2025</p><p>The Honorable Morgan Griffith<br>U.S. House of Representatives<br>2110 Rayburn House Office Building<br>Washington, DC 20515</p><p>Dear Representative Griffith:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners 鈥� including more than 270,000 affiliated physicians, 2 million nurses and other caregivers 鈥� and the 43,000 health care leaders who belong to our professional membership groups, the 黑料正能量 Association (AHA) writes to express our opposition to H.R. 2191, the Physician Led and Rural Access to Quality Care Act.</p><p>Rural hospitals are essential access points for care, economic anchors for their communities, and the backbone of our nation鈥檚 rural communities. These hospitals have maintained their commitment to ensuring local access to high-quality, affordable care despite continued financial and workforce challenges. The AHA strongly supports legislation that would enable rural hospitals across the nation to better care for their communities. However, we believe that H.R. 2191 is misguided legislation that would skew the health care marketplace in favor of physicians who self-refer patients to hospitals they own and would destabilize rural health care while failing to improve access to quality care.</p><p>H.R. 2191 would result in additional gaming of the Medicare program, jeopardize patient access to emergency care, potentially harm sicker and lower-income patients, and severely damage the ability of 24/7 full-service community hospitals to provide care in rural areas.</p><p>Physician self-referral 鈥� whether in rural, suburban or urban communities 鈥� is the antithesis of fair competition. The problematic practice allows physicians to steer their most profitable cases to facilities they own 鈥� facilities that often call 9-1-1 to handle their emergencies and are often located in the most affluent areas. By performing the highest-paying procedures for the best-insured patients, physician-owners inflate health care costs and drain essential resources from community hospitals, which depend on a balance of services and patients to provide indispensable treatment, such as behavioral health and trauma care. By increasing the presence of these self-referral arrangements, H.R. 2191 would only further destabilize community care.</p><p>Since the Medicare Modernization Act of 2003, Congress has supported ending the egregious and costly practice of physician self-referral to hospitals they own. Current law represents a 15-year compromise that (1) allows existing physician-owned hospitals (POHs) to continue to treat Medicare patients, (2) permits the expansion of those physician-owned hospitals that meet communities鈥� needs for additional hospital capacity and treat low-income patients, and (3) prohibits Medicare from covering services in any new physician-owned hospitals established after Dec. 31, 2010. Congress established these guardrails to protect the Medicare program from overutilization, patient steering and the harmful patient selection practices that POHs employ.</p><p>Data have shown time and time again that POHs select only the healthiest and most profitable patients, serving lower proportions of Medicaid, dual eligible and uncompensated care than full-service acute care hospitals. The <a href="https://www.cbo.gov/sites/default/files/111th-congress-2009-2010/costestimate/amendreconprop.pdf" target="_blank" title="Congressional Budget Office Website">Congressional Budget Office</a>, the <a href="https://www.medpac.gov/wp-content/uploads/import_data/scrape_files/docs/default-source/reports/Mar05_SpecHospitals.pdf" target="_blank" title="Medicare Payment Advisory Commission">Medicare Payment Advisory Commission</a> and the <a href="https://public-inspection.federalregister.gov/2023-16252.pdf" target="_blank" title="Center for Medicare & Medicaid Services">Centers for Medicare & Medicaid Services</a> all have concluded that physician self-referral leads to greater per capita utilization of services and higher costs for the Medicare program, among other negative impacts.</p><p>For these reasons, the AHA strongly opposes the expansion of POHs 鈥� by either creating new categories of exceptions or allowing existing POHs to expand 鈥� and cannot support H.R. 2191. Congress should maintain current law, preserve the ban on physician self-referrals to new physician-owned hospitals, and retain restrictions on the growth of existing physician-owned hospitals, regardless of location.</p><p>Sincerely,</p><p>/s/</p><p>Lisa Kidder Hrobsky<br>Senior Vice President, Advocacy and Political Affairs</p> Thu, 27 Mar 2025 10:36:14 -0500 Physician Self-Referral Law/Stark law /news/perspective/2023-08-18-keeping-brakes-physician-owned-hospitals-best-patients <p>Fair competition has always been the driving principle of our nation鈥檚 economy. This includes health care, and it鈥檚 the reason the Ethics in Patient Referrals Act, more commonly known as the 鈥淪tark Law,鈥� has been on the books for decades to protect the Medicare program from the inherent conflict of interest created when physicians self-refer their patients to facilities and services in which they have a financial stake.</p> <p>But the Stark Law鈥檚 鈥渨hole hospital鈥� exception permitted physicians to refer patients to those hospitals where they had an ownership interest in the entire facility rather than just in a subdivision, such as imaging or surgery. In 2010, Congress closed the 鈥渨hole hospital鈥� exception loophole, except for grandfathered hospitals.</p> <p><strong>Closing the loophole made good sense then, and it makes even better sense now.</strong></p> <p>We鈥檙e concerned that some members of Congress want to roll back this basic patient protection by eliminating Medicare鈥檚 prohibition on physician self-referral to new physician-owned hospitals (POHs) and all restrictions on their growth.</p> <p><strong>Backing up 15 years of research, a <a href="/guidesreports/2023-08-03-new-analysis-validates-need-preserve-restrictions-growth-physician-owned-hospitals?utm_source=newsletter&utm_medium=email&utm_campaign=aha-today" target="_blank">new report</a> from Dobson | DaVanzo helps cement the powerful case for Congress to maintain current law, preserve the ban on physician self-referrals to new POHs and retain restrictions on the growth of existing POHs.</strong></p> <p>This new study found that POHs report on fewer Medicare quality measures and perform worse on readmission penalties than full-service community hospitals, demonstrating that POHs are fundamentally different from full-service community hospitals 鈥� they treat fewer patients, provide fewer services and do not meet as wide a range of patient clinical needs.</p> <p>This report and others have shown the adverse impact POHs have had on:</p> <p>Patient Selection 鈥� The <strong><a href="/news/headline/2023-03-28-study-reaffirms-need-ban-self-referral-physician-owned-hospitals?utm_source=newsletter&utm_medium=email&utm_campaign=aha-today" target="_blank">Dobson | DaVanzo report</a></strong> reinforced earlier findings  that POHs treat younger, less medically complex patients who are less likely to be enrolled in Medicare or Medicaid. Physician-owners鈥� practice of selecting the healthiest and wealthiest patients and avoiding less profitable Medicaid and uninsured patients creates a destabilizing environment that leaves sicker and less-affluent patients to community hospitals, threatening the health care safety net.</p> <p><u>Access</u> 鈥� POHs provide limited or no emergency services, relying instead on publicly funded 911 services when their patients need emergency care. In fact, a Department of Health and Human Services鈥� report found that a third of POHs 鈥渦se 911 to obtain medical assistance to stabilize patients, a practice that may violate Medicare requirements.鈥�</p> <p><u>Cost</u> 鈥� According to the Congressional Budget Office, physician self-referral leads to greater utilization of services and higher health care costs. Closing the 鈥渨hole hospital鈥� exception loophole to the Stark Law reduced the federal deficit by $500 million over 10 years, according to CBO.</p> <p>But some members of Congress support ill-advised legislation (H.R. 977/S. 470) that would repeal current law 鈥� eliminating all restrictions on POHs, allowing unfettered growth of these arrangements, and raising the deficit at a time when our nation is trying to control increases in health care costs.</p> <p>Preventing physician-owners from steering patients to facilities in which they have a financial stake is a sensible 鈥渇irst, do no harm鈥� policy. This latest analysis once again reaffirms the need to maintain current law banning physician self-referrals to new POHs and restricting the growth of existing POHs.</p> <h2><strong>Hawaii Wildfires</strong></h2> <p>Americans everywhere have watched with shock, dismay and alarm as the deadliest wildfire in modern U.S. history devastated the beautiful island of Maui, exacting a terrible toll in lives lost and injured while causing vast damage to homes, businesses and property 鈥� including vital health care clinics and medical supplies. Once again, it was our front-line responders who first answered the cries for help.</p> <p>Meanwhile, our hospitals, health systems and care teams are tending to the injured. And our health care workers continue to put the needs of their patients and communities first, even as many of them have lost so much.</p> <p>The AHA stands with our colleagues at The Healthcare Association of Hawaii, which has shared a list of organizations that are supporting the victims. They are:</p> <ul> <li><a href="https://www.hawaiicommunityfoundation.org/maui-strong">Hawaii Community Foundation鈥檚 Maui Strong Fund</a></li> <li><a href="https://mauifoodbank.org/donate/" target="_blank">Maui Food Bank</a></li> <li><a href="https://www.gofundme.com/f/hawaii-chamber-foundation-business-relief-fund" target="_blank">Hawaii Chamber of Commerce Foundation Business Relief Fund</a></li> <li><a href="https://ignite.stratuslive.com/auw/get-involved/donate/mauirelief" target="_blank">Aloha United Way Maui Fire Relief Fund</a></li> </ul> <p>We join with all Americans in extending our support, hope and prayers to all those affected by this natural disaster as Hawaiians face the challenging road to recovery.</p> Fri, 18 Aug 2023 09:09:08 -0500 Physician Self-Referral Law/Stark law /news/headline/2023-08-03-study-physician-owned-hospitals-perform-worse-readmissions-report-fewer-quality-measures <p>As some members of Congress propose to weaken Medicare鈥檚 prohibition on physician self-referral to new physician-owned hospitals and ease restrictions on their growth, <a href="/guidesreports/2023-08-03-analysis-selected-medicare-quality-measure-reporting-data-hospital-ownership">new data from Dobson | DaVanzo</a> show that POHs publicly report on fewer Medicare quality measures and perform worse on readmission penalties than full-service community hospitals. The study also reinforces previous findings that POHs generally treat a population that is younger, less medically complex and less likely to be enrolled in Medicare or Medicaid. <br />  <br /> 鈥淭his new analysis adds to more than 15 years of research suggesting that POHs select their patients by avoiding less profitable Medicaid and uninsured patients, treat fewer medically complex patients, and provide fewer emergency services,鈥� AHA and the Federation of 黑料正能量s note in a <a href="/guidesreports/2023-08-03-new-analysis-validates-need-preserve-restrictions-growth-physician-owned-hospitals">one-pager</a> on the report. 鈥淏eyond validating findings by the Government Accountability Office, Health and Human Services Office of Inspector General, and the Medicare Payment Advisory Commission that POHs do not treat the same scope, complexity, or acuity of patients as non-POHs within the same market, this analysis also shows that POHs have higher average penalties for readmissions compared to full-service community hospitals. In short, by choosing the healthiest and wealthiest patients, POHs pose program integrity, access and health equity risks for the Medicare program.鈥� </p> Thu, 03 Aug 2023 15:02:00 -0500 Physician Self-Referral Law/Stark law /guidesreports/2023-08-03-new-analysis-validates-need-preserve-restrictions-growth-physician-owned-hospitals <div class="container"> <div class="row"> <div class="col-md-8"> <p><strong><span>As some members of Congress continue to propose weakening Medicare鈥檚 prohibition on physician self-referral to new </span><a href="/fact-sheets/2023-02-27-fact-sheet-physician-self-referral-physician-owned-hospitals" target="_blank">physician-owned hospitals (POHs)</a><span> and loosening restrictions on the growth of existing POHs, new data from </span><a href="/guidesreports/2023-08-03-analysis-selected-medicare-quality-measure-reporting-data-hospital-ownership">Dobson | DaVanzo</a><span> show that POHs report fewer quality measures and perform worse on readmission penalties compared to full-service community hospitals.</span></strong> Hospital Star Ratings are reported on the Centers for Medicare & Medicaid Services鈥� (CMS) Care Compare website, and these ratings allow the public to compare hospitals鈥� performance based on standardized quality metrics.</p> <p>This new analysis reinforces <strong><a href="/news/blog/2023-04-24-physician-owned-hospitals-are-bad-patients-and-communities">previous findings</a></strong> that POHs generally treat a population that is younger, less complex or comorbid, and less likely to be dually eligible for Medicare and Medicaid. Despite treating a healthier and better insured population than similarly situated community hospitals, POHs received higher readmission penalties from CMS. This new study found that:</p> <ul> <li><span><strong>POHs generally report fewer quality measures within each measure domain of Medicare鈥檚 Hospital Star Ratings compared to general full-service acute care hospitals.</strong></span> On average, POHs reported fewer measures compared to general acute care hospitals for patient safety (2.8 vs. 5.0 measures), readmissions (4.3 vs. 7.7 measures), and timely and effective care (2.9 vs. 6.4 measures). The fact that POHs report on fewer quality measures demonstrates that they are fundamentally different from full-service community hospitals 鈥� they treat fewer patients (and therefore may not reach thresholds for reporting), provide fewer services and do not meet as wide a range of patient clinical needs.</li> <li><span><strong>POHs are more likely to be in the lowest peer group for Hospital Readmissions Reduction Program (HRRP) reporting and perform worse than other hospitals within their own peer group.</strong></span> Peer groups in the HRRP are defined based on the proportion of a hospital鈥檚 care that is provided to patients who are dual-eligible for Medicare and Medicaid. Specifically, 78% of POHs were in the lowest dual-eligible peer group for HRRP reporting compared to 19% of general acute care facilities. This finding validates prior research showing that POHs treat far fewer dual-eligible patients than general acute care hospitals.</li> <li><span><strong>POHs performed worse than full-service community hospitals on readmission metrics as part of the HRRP, which reduces Medicare payments to hospitals with excess readmissions.</strong></span> Even though POHs treat younger, less medically complex patients with fewer comorbidities, the report shows that POHs had higher average penalties (0.4% payment reduction vs. 0.3% payment reduction), and a much higher percentage of POHs received the maximum payment penalty compared to general acute care hospitals in the same lowest dual-eligible peer group and market (6.7% vs. 0.5%). At least eight POHs in the lowest peer group received the maximum readmission penalty, which is notable considering only 17 total hospitals (both POH and non-POH) across all five peer groups received the maximum penalty in 2023 and only 10 total hospitals received the maximum penalty in the lowest peer group.<sup><a href="#fn1">1</a></sup></li> </ul> <p>This new analysis adds to more than 15 years of research suggesting that POHs select their patients by avoiding less profitable Medicaid and uninsured patients, treat fewer medically complex patients, and provide fewer emergency services. Beyond validating findings by the Government Accountability Office, <strong><a href="https://oig.hhs.gov/oei/reports/oei-02-06-00310.pdf" target="_blank">Health and Human Services Office of Inspector General</a></strong>, and the <strong><a href="https://www.medpac.gov/wp-content/uploads/import_data/scrape_files/docs/default-source/reports/Mar05_SpecHospitals.pdf" target="_blank">Medicare Payment Advisory Commission</a></strong> that POHs do not treat the same scope, complexity, or acuity of patients as non-POHs within the same market, this analysis also shows that POHs have higher average penalties for readmissions compared to full-service community hospitals. In short, by choosing the healthiest and wealthiest patients, POHs pose program integrity, access and health equity risks for the Medicare program.</p> <p><span><strong>The latest analysis from Dobson | DaVanzo once again reaffirms the need to maintain current law banning physician self-referrals to new POHs and restricting the growth of existing POHs.</strong></span></p> <hr> <ol> <li id="fn1"><a href="https://kffhealthnews.org/news/hospital-penalties/readmissions/" target="_blank">https://kffhealthnews.org/news/hospital-penalties/readmissions/</a></li> </ol> </div> <div class="col-md-4"> <div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2023/08/New-Analysis-Validates-Need-to-Preserve-Restrictions-on-the-Growth-of-Physician-owned-Hospitals.pdf" target="_blank" title="Click here to download the New Analysis Validates Need to Preserve Restrictions on the Growth of Physician-owned Hospitals PDF.">Click here to download the Overview PDF</a></div> <p><a href="/system/files/media/file/2023/08/New-Analysis-Validates-Need-to-Preserve-Restrictions-on-the-Growth-of-Physician-owned-Hospitals.pdf" target="_blank" title="Click here to download the New Analysis Validates Need to Preserve Restrictions on the Growth of Physician-owned Hospitals PDF."><img alt="New Analysis Validates Need to Preserve Restrictions on the Growth of Physician-owned Hospitals page 1." data-entity-type="file" data-entity-uuid="c0138c7a-1726-47bb-ab9e-5f89bc11a1b3" src="/sites/default/files/inline-images/Page-1-New-Analysis-Validates-Need-to-Preserve-Restrictions-on-the-Growth-of-Physician-owned-Hospitals.png" width="691" height="900"></a></p> </div> </div> </div> Thu, 03 Aug 2023 06:15:00 -0500 Physician Self-Referral Law/Stark law /guidesreports/2023-08-03-analysis-selected-medicare-quality-measure-reporting-data-hospital-ownership <div class="container"> <div class="row"> <div class="col-md-8"> <h2>Introduction</h2> <p>Dobson | DaVanzo recently examined Medicare claims data comparing demographic and clinical characteristics of facilities and patients receiving care at physician-owned hospitals (POHs) and all other acute care hospitals (non-POHs). That report showed that relative to POHs, non-POHs care for older, more medically complex patients who are on average burdened with multiple co-morbid conditions, while also operating on lower margins and providing more uncompensated and unreimbursed care. Building on this work, we now investigate to what extent differences exist among these hospital groups on their reporting and performance in Medicare鈥檚 Hospital Star Rating Domains and Hospital Readmissions Reduction Program (HRRP).<sup><a href="#fn1">1</a></sup> This document outlines the data and methods used and summarizes preliminary findings.</p> <h2>Data and Methods</h2> <p>The POHs represented in this fact sheet were identified based primarily on a June 2016 Physician Hospitals of America list and subsequent FAH/AHA review. Non-POHs are defined as the remaining acute care hospitals that are paid under the inpatient hospital prospective payment system (IPPS) defined under Section 1886(d) of the Social Security Act.<sup><a href="#fn2">2</a></sup> For this analysis, market areas are defined as hospital referral regions (HRRs) from the Dartmouth Atlas of Healthcare, which are made up of zip code area groupings based on the referral patterns of tertiary medical care.<sup><a href="#fn3">3</a></sup> Using data from the January 2023 Hospital General Information file and FY 2023 Hospital Readmissions Reduction Program (HRRP) Supplemental file produced by CMS, we conducted descriptive analyses to compare POHs with non-POHs in POH market areas. POH market areas are defined as any HRR with at least one POH.</p> <h2>Hospital Compare Star Rating Domains Analysis Findings</h2> <p>As shown in Table 1 below, POHs generally reported fewer measures in each of the Hospital Compare Star Rating domains as compared to non-POHs in POH markets. The one exception is the Patient Experience domain, where POHs report a slightly higher average number of measures as compared to non-POHs in POH markets. This further demonstrates that POHs do not treat the same scope, complexity or acuity of patients compared to non-POHs.</p> <hr> <h3>Table 1: Average Count of Measures used in the Overall Hospital Compare Star Rating by Domain, POH vs. Non-POH in POH Markets</h3> <table> <tbody> <tr> <th>Hospital Group</th> <th>Number of Hospitals</th> <th>Average Count of Facility Mortality Measures</th> <th>Average Count of Facility Safety Measures</th> <th>Average Count of Facility Readmission Measures</th> <th>Average Count of Facility Patient Experience Measures</th> <th>Average Count of Facility Timely and Effective Care Measures</th> </tr> <tr> <td>POH</td> <td>158</td> <td>1.3</td> <td>2.8</td> <td>4.3</td> <td>7.1</td> <td>2.9</td> </tr> <tr> <td>Non-POHs in POH Markets</td> <td>1,184</td> <td>4.6</td> <td>5.0</td> <td>7.7</td> <td>7.0</td> <td>6.4</td> </tr> <tr class="bold-faced"> <td>Total</td> <td>1,342</td> <td>4.2</td> <td>4.7</td> <td>7.3</td> <td>7.0</td> <td>6.0</td> </tr> <tr class="bold-faced"> <td>% Difference (POH and Non-POH)</td> <td> </td> <td>111.7%</td> <td>55.4%</td> <td>56.1%</td> <td>2.6%</td> <td>75.4%</td> </tr> </tbody> </table> <p>Notes:</p> <p>Non-acute care hospitals, hospitals that do not participate in in the Inpatient Quality Reporting (IQR) and Outpatient Quality Reporting (OQR) programs (identified via Hospital General Information file footnote 19), and Department of Defense hospitals are excluded.</p> <p>Non-POH hospitals are restricted to those located in the same market as a POH (86 HRRs).</p> <p>The count of facility measures was set to 0 for a facility's domain when the count of measures reported was 'not available' and CMS General information file footnote 5 ('Results are not available for this reporting period') was present.</p> <p>Data shown are rounded to the nearest tenth decimal place. Percent difference is calculated from the unrounded POH and Non-POH average measure count data. Source: Dobson | DaVanzo analysis of 2023 Hospital General Information file produced by CMS.</p> <hr> <h2>Hospital Readmissions Reduction Program (HRRP) Analysis Findings</h2> <p>Hospitals are organized into peer groups in the Hospital Readmissions Reduction Program to measure relative performance on HRRP measures among hospitals that are similarly situated. Congress mandated that CMS implement peer groups in the HRRP beginning on October 1, 2018 in order to account for the influence of health-related social needs on readmissions performance. Peer grouping is designed to facilitate more equitable performance comparisons and payment adjustments across hospitals in the HRRP. These peer groups are defined based on the proportion of a hospital鈥檚 care provided to patients who are dually-eligible for Medicare and Medicaid. Dual-eligible proportion is intended to serve as a proxy for the prevalence of health-related social needs among the patients that hospitals serve. Hospitals are peer grouped with other hospitals serving similar proportions of dual-eligible patients and have their readmissions measure performance compared to other hospitals within their peer group.</p> <p>Based on an analysis of FY 2023 HRRP results, the majority of POHs fall into the lowest dual-eligible proportion peer group, which indicates that they treat smaller proportions of dual-eligible patients as compared to non-POHs. Additional detail is shown in Chart 1, below.</p> <h3>Chart 1: Distribution of Hospitals in HRRP Peer Groups in POH Markets</h3> <p><img alt="Distribution of Hospitals in HRRP Peer Groups in POH Markets. HRRP Peer Groups go from lower proportion of dual-eligible patients to higher proportion of dual eligible patients. Group 1: 78% of POHs; 19% of Non-POHs in POH Markets. Group 2: 7% of POHs; 24% of Non-POHs in POH Markets. Group 3: 6% of POHs; 23% of Non-POHs in POH Markets. Group 4: 4% of POHs; 18% of Non-POHs in POH Markets. Group 1: 5% of POHs; 16% of Non-POHs in POH Markets. Source: Dobson | DaVanzo analysis of FY 2023 Hospital Readmissions Reduction Program (HRRP) Supplemental file produced by CMS." data-entity-type="file" data-entity-uuid="8f7ffe68-5706-4918-82d2-13d7cf9a837c" src="/sites/default/files/inline-images/Chart-1-Distribution-of-Hospitals-in-HRRP-Peer-Groups-in-POH-Markets.jpg" width="1181" height="790"></p> <p><small>Source: Dobson | DaVanzo analysis of FY 2023 Hospital Readmissions Reduction Program (HRRP) Supplemental file produced by CMS.</small></p> <p>This finding is consistent with our prior report showing that non-POHs competing with POHs treated 10.7% more dual-eligible patients relative to POHs. In addition, because POHs tend to specialize in selected medical conditions, only 1.3 of the 5 conditions<sup><a href="#fn4">4</a></sup> on average have sufficient volume (25 cases or more) volume to qualify for the HRRP composite measure compared to an average of 3.5 conditions for non-POHs in the Lowest Dual-Eligible Proportion Peer Group. Although the HRRP composite metric consists of only specific conditions that POHs treat, they receive higher Medicare penalties than non-POHs that treat a broader set of conditions and are subjected to more conditions included in the HRRP composite measure. Additional detail is provided in the points and Table 2, below.</p> <ul> <li>119 POHs (78% of all POHs) were in the lowest dual-eligible proportion peer group compared to 216 non-POHs (19% of all non-POHs). Hospitals in this peer group have the lowest proportion of dual-eligible patients.</li> <li>Of the 119 POHs in the lowest dual-eligible proportion peer group, 8 hospitals (6.7%) received the maximum HRRP penalty of 3% in FY2023, compared to only 1 of the 216 non-POHs (0.5%) in the same market.</li> <li>The average HRRP payment reduction percentage for POHs in the lowest dual-eligible proportion peer group was 0.4% compared to non-POHs in the same market of 0.3%.</li> <li>On average only 1.3 of the 5 conditions4 have enough volume to qualify for the HRRP composite measure for POHs in the lowest dual-eligible proportion peer group compared to 3.5 for non-POHs in the same market and dual-eligible proportion peer group.</li> </ul> <hr> <h3>Table 2: Medicare HRRP Penalties and Average Number of Conditions Eligible for HRRP Composite Measure for POHs Compared to Non-POHs in the Lowest Dual-Eligible Proportion Peer Group</h3> <table> <tbody> <tr> <th>Hospital Group</th> <th>Number of Hospitals</th> <th>Average HRRP Payment Reduction Percentage</th> <th>Percent Hospitals with Max HRRP Penalty</th> <th>Average Number of Conditions Eligible for HRRP Composite Measure</th> </tr> <tr> <td>POHs</td> <td>119</td> <td>0.4%</td> <td>6.7%</td> <td>1.3</td> </tr> <tr> <td>Non-POHs in POH Markets</td> <td>216</td> <td>0.3%</td> <td>0.5%</td> <td>3.5</td> </tr> </tbody> </table> <p>Notes:</p> <p>POHs and non-POHs were stratified based on dual-eligibility peer group, which consists of five peer groups based on the hospital鈥檚 dual proportion.<sup><a href="#fn5">5</a></sup></p> <p>The HRRP measure is a composite metric that includes hospital excess readmission rates within five conditions/procedures.<sup><a href="#fn6">6</a></sup></p> <p>A hospital must have at least 25 Medicare discharges within condition/procedure for that condition/procedure to be included in the composite metric.</p> <p>Source: Dobson | DaVanzo analysis of FY 2023 Hospital Readmissions Reduction Program (HRRP) Supplemental file produced by CMS.</p> <hr> <h2>Conclusion</h2> <p>As compared to non-POHs in the same market as a POH, POHs appear to report fewer measures in most of the CMS Hospital Compare Star Ratings Domains and are less likely to have adequate volume to qualify for the full breadth of HRRP measures. This suggests POHs are accountable for a narrower scope of quality measure performance than non-POHs. POHs have sometimes asserted that offering more focused services facilitates stronger quality performance. Yet, this analysis shows POHs appear to have slightly higher average readmission penalties. POHs also are disproportionately more likely than similarly situated non-POH hospitals to experience the maximum HRRP penalty. These findings build on our prior work that shows POHs care for a less medically complex Medicare population than non-POHs./p></p> <hr> <ol> <li id="fn1">This study was commissioned by the Federation of 黑料正能量s (FAH) and the 黑料正能量 Association (AHA).</li> <li id="fn2">Critical Access Hospitals (small rural hospitals), Psychiatric Hospitals, Inpatient Rehabilitation Facilities, Long Term Care Hospitals, and Pediatric Hospitals are excluded.</li> <li id="fn3"><a href="https://www.dartmouthatlas.org/research-methods/" target="_blank">https://www.dartmouthatlas.org/research-methods/</a>.</li> <li id="fn4">4 Note that six measures are typically included in HRRP. However, CMS suppressed one of the measures (pneumonia readmissions) for FY 2023 due to the COVID-19 Public Health Emergency; see <a href="https://qualitynet.cms.gov/inpatient/hrrp/measures" target="_blank">https://qualitynet.cms.gov/inpatient/hrrp/measures</a>.</li> <li id="fn5">Dual proportion is the proportion of Medicare fee-for-service (FFS) and managed care stays in a specific hospital, where the patient was dually eligible for Medi-care and full-benefit Medicaid during the FY 2018 HRRP performance period (July 1, 2013 to June 30, 2016).</li> <li id="fn6">Acute myocardial infarction, chronic obstructive pulmonary disease, heart failure, coronary artery bypass graft, and elective primary total hip and/or knee arthroplasty.</li> </ol> </div> <div class="col-md-4"> <p><a href="/system/files/media/file/2023/08/Analysis-of-Selected-Medicare-Quality-Measure-Reporting-Data-by-Hospital-Ownership.pdf" target="_blank" title="Click here to download the Analysis of Selected Medicare Quality Measure Reporting Data by Hospital Ownership report PDF."><img alt="Analysis of Selected Medicare Quality Measure Reporting Data by Hospital Ownership page 1." data-entity-type="file" data-entity-uuid="ee790405-64bc-4c09-8a66-33987dd21320" src="/sites/default/files/inline-images/Page-1-Analysis-of-Selected-Medicare-Quality-Measure-Reporting-Data-by-Hospital-Ownership.png" width="695" height="900"></a></p> </div> </div> </div> table, th, td { border: 1px solid black; border-collapse: collapse; } tr.bold-faced { font-weight: bold; } th { background-color: #78be2026; } Thu, 03 Aug 2023 06:00:00 -0500 Physician Self-Referral Law/Stark law /news/blog/2023-06-29-new-study-validates-risks-expanding-physician-owned-hospitals <p><span><span><span><span><span>A </span></span><a href="https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2806510"><span><span>new study</span></span></a><span><span> funded by Patient Rights Advocate adds to the evidence that physician-owned hospitals (POHs) are not comparable to or substitutes for full-service acute care hospitals. Buried beneath its flawed conclusions on hospital prices are three simple truths: the study was based on a very limited sample size (just eight medical procedures), it relies on misleading data, and, most importantly, <b>the study鈥檚 own data shows conclusively that POHs shun medically complex patients, as well as the uninsured and those on Medicaid.</b></span></span></span></span></span></p> <p><span><span><span><span><span>The study finding lower prices on eight self-selected procedures obscures the reality proven time and again that expanding POHs would actually increase overall costs to patients, employers, and the federal government, and destabilize access to critical and higher acuity hospital-based services in communities across the country.</span></span></span></span></span><br />  </p> <p><span><span><span><span><span>Specific issues with the study include: </span></span></span></span></span></p> <p> </p> <ul> <li><span><span><span><b><span><span>Limited sample of procedures: </span></span></b><span><span>The study only evaluates a small, self-selected set of eight medical procedures. Perhaps this is because the authors recognize that POHs do not provide the full breadth of services that full-service acute care hospitals provide, as a majority of POHs only offer care for specific services like orthopedic or cardiac care at their facilities. It鈥檚 impossible to draw any meaningful conclusions from such an incomplete sample.</span></span><br /> <span><span> </span></span></span></span></span></li> <li><span><span><span><b><span><span>Relies on misleading data:</span></span></b><span><span> The most substantial flaw is in the authors鈥� reliance on price transparency data rather than claims data. The truth is price transparency data does not necessarily reflect what a provider is actually paid for an episode of care. For example, payers routinely deny claims in whole or in part, thus reducing the actual value of what is paid. The rates in the price transparency files also do not account for myriad other factors that could impact the actual amount paid, such as whether the service was one of several the patient received during an episode of care or whether the payment was based in part on performance-based adjustments.<br /> <br /> At the most extreme example, using the price transparency files runs the risk that the authors are comparing prices for services a POH may not even provide due to 鈥済host rates鈥� that are known to exist in the transparency files. Take, for example, emergency services. The study compares prices for certain emergency department procedures but fails to acknowledge that POHs provide far fewer emergency services 鈥� if any at all 鈥� to patients than non-POHs, as </span></span><a href="/fact-sheets/2023-03-28-select-financial-operating-and-patient-characteristics-pohs-compared-non-pohs-fact-sheet"><span><span>prior research</span></span></a><span><span> has found. Instead POHs generally shift costs for these services, relying on publicly funded 911 services or general acute care hospitals when their patients need emergency care.</span></span></span></span></span><br />  </li> <li><span><span><span><b><span><span>Ignores POHs鈥� patient mix: </span></span></b><span><span>The authors discount the impact of POHs treating a far less medically complex patient population than full-scale acute care hospitals, something that directly impacts the cost of providing care. <b>In other words, POHs select a set of high-margin services to provide to healthier patients who have more generous insurance. </b>For example, the study finds that full-service acute care hospitals treated more than twice as many Medicaid patients and provided nearly three times as much charity care as POHs, a population that is well-documented to be more medically complex, sicker, and higher cost to care for than other patients. </span></span></span></span></span></li> </ul> <p><span><span><span><span><span>These findings, along with the fact that POHs enjoyed significantly higher financial margins as a result, are entirely consistent with <a href="/fact-sheets/2023-03-28-select-financial-operating-and-patient-characteristics-pohs-compared-non-pohs-fact-sheet">prior research</a> and with previous findings from the Government Accountability Office, the Centers for Medicare & Medicaid Services, the Medicare Payment Advisory Commission, and others. </span></span><span><span>The implications of this patient selection on affordability and access to care led Congress to ban new POHs and restrict the growth of existing facilities thirteen years ago. <b>This study only reinforces Congress鈥� concerns amid calls by some to repeal restrictions on POHs</b>.</span></span></span></span></span></p> <p><span><span><span><span><span>In short, this study adds to a growing body of evidence that bolsters the need to maintain current law on POHs. At the same time, it makes unsubstantiated claims based on flawed data about the value of POHs. Congress must consider the far-reaching implications of repealing current law: less access for the nation鈥檚 medically underserved, more expensive hospital care for all patients, and an increase in the federal deficit. </span></span></span></span></span></p> <p><em><span><span><span><span><span>Stacey Hughes is the 黑料正能量 Association's executive vice president. Chip Kahn is the Federation of 黑料正能量's president and CEO.</span></span></span></span></span></em></p> Thu, 29 Jun 2023 10:33:24 -0500 Physician Self-Referral Law/Stark law /news/headline/2023-04-24-aha-fha-blog-says-physician-owned-hospitals-are-bad-patients-and-communities <p>Physician-owned hospitals are 鈥渘ot good for patients, communities, the integrity of the Medicare program, or providers who are actually in the business of caring for all patients, 24/7, regardless of their ability to pay or their medical condition,鈥� the AHA and Federation of 黑料正能量s wrote today in a <a href="/news/blog/2023-04-24-physician-owned-hospitals-are-bad-patients-and-communities">blog post</a>.  <br />  <br /> The blog highlights new data from the health care consulting firm Dobson | Davanzo reaffirming that POHs cherry-pick patients by avoiding the less profitable Medicaid and uninsured patients; treat fewer medically complex patients; and provide fewer emergency services and often rely on publicly funded 911 services and acute care, community hospitals for these services for their own patients. <br />   <br /> In addition, the blog highlights how the Centers for Medicare & Medicaid Services recently reinforced the need for the ban on new POHs and restrictions on the growth of existing facilities. In this month鈥檚 inpatient prospective payment system proposed rule, CMS proposed to reinstate program integrity restrictions for POHs approved as 鈥渉igh Medicaid facilities鈥� due to the risk for patients and the Medicare program.   </p> Mon, 24 Apr 2023 15:12:08 -0500 Physician Self-Referral Law/Stark law /news/blog/2023-04-24-physician-owned-hospitals-are-bad-patients-and-communities <p>For decades, the Ethics in Patient Referrals Act (鈥淪tark Law鈥�) has protected the Medicare program, its beneficiaries and communities from the inherent conflict of interest created when physicians self-refer their patients to facilities and services they own. Recently the Federation of 黑料正能量s (FAH) and the 黑料正能量 Association (AHA) released <a href="/fact-sheets/2023-03-28-select-financial-operating-and-patient-characteristics-pohs-compared-non-pohs-fact-sheet">new data</a> from the health care consulting firm Dobson | Davanzo reaffirming what prior analyses from the Department of Health and Human Services鈥� Office of Inspector General, the Government Accountability Office, and the Medicare Payment Advisory Commission have all shown 鈥� physician-owned hospitals (POHs):</p> <ul> <li>Cherry-pick patients by avoiding the less profitable Medicaid and uninsured patients;</li> <li>Treat fewer medically complex patients; and</li> <li>Provide fewer emergency services and often rely on publicly funded 911 services and acute care, community hospitals for these services for their own patients.</li> </ul> <p>For these reasons, Congress enacted a ban on new POHs and restrictions on the growth of existing facilities. POHs are allowed to expand if they are certified as 鈥渉igh Medicaid facilities鈥� and can demonstrate a need for additional beds in their service area.</p> <p>Recently, the Centers for Medicare & Medicaid Services (CMS) once again reinforced the need for this law, proposing to reinstate program integrity restrictions for POHs approved as 鈥渉igh Medicaid facilities鈥� due to the risk for patients and the Medicare program. <strong>In the 2024 Inpatient Prospective Payment System Proposed Rule, CMS said: 鈥淚t is our position that protecting the Medicare program and its beneficiaries, as well as Medicaid beneficiaries, uninsured patients, and other underserved populations, from harms such as overutilization, patient steering, cherry-picking, and lemon-dropping outweighs any perceived burden on high Medicaid facilities.鈥�</strong></p> <p>Despite these facts, proponents of repealing current law continue their attempts to discredit what the data clearly show. Their latest attempt completely misrepresents the findings of the Dobson | Davanzo analysis, citing outdated data and ignoring key metrics and the larger patient population included in the study. For example, they erroneously claim that the study uses only Medicare claims data for beneficiaries 85 and older. In fact, the Dobson | DaVanzo study is based on a review of all Medicare beneficiary claims; the analysis provides the additional example that POHs treat far fewer beneficiaries 85 and older (often the most vulnerable and medically complex Medicare beneficiaries) than non-POHs. Additionally, they confuse readmission rates with the percent of hospitals that experience the maximum 3% readmissions penalty, which is the metric included in the study. Once again, the data show that POHs are far more likely to experience the maximum readmission penalty than non-POHs.</p> <p><strong>It is time to face the facts and acknowledge that POHs are not good for patients, communities, the integrity of the Medicare program, or providers who are actually in the business of caring for all patients, 24/7, regardless of their ability to pay or their medical condition.</strong></p> <p><em>Chip Kahn is the president and CEO of the Federation of 黑料正能量s. Stacey Hughes is the executive vice president of government relations and public policy at the 黑料正能量 Association.</em></p> Mon, 24 Apr 2023 06:05:45 -0500 Physician Self-Referral Law/Stark law <div class="container"><div class="row"><div class="col-md-8"><p>Several House subcommittees April 26 will hold hearings on a variety of issues that affect hospitals and health systems, including transparency, site-neutral payment policies, tax-exempt status, workforce shortages and the Provider Relief Fund. One of the hearings at the House Energy and Commerce Subcommittee on Health is a legislative hearing that will <a href="https://energycommerce.house.gov/posts/chairs-rodgers-guthrie-announce-bipartisan-health-subcommittee-legislative-hearing-on-transparency-and-competition" target="_blank">discuss a number of proposals</a> released yesterday, including ones on site-neutral payments, the 340B Drug Pricing Program, price transparency and physician-owned hospitals, among other issues.</p><p>Additional details about the hearings follow, as well as resources that can assist your advocacy efforts with your lawmakers.</p><h2>Take Action Today</h2><p><strong>If you have a representative on the House subcommittees holding hearings next week, please reach out to them prior to the hearings to ensure they understand the financial challenges facing your hospital or health system, the impact of these challenges on your community, and the dire need for congressional support 鈥� not policies that would jeopardize access to patient care, further threaten the financial stability of the field or add burden to an already overwhelmed workforce.</strong></p><p>Even if you do not have a representative on one of the committees meeting next week, it is important that your lawmaker hear from you on these issues. Ongoing education of Congress is a vital step in securing additional support for the field and preventing damaging legislation that may affect hospitals and health systems鈥� ability to continue to provide services to their communities.</p><h3>Energy and Commerce Subcommittee on Health Legislative Hearing</h3><p>The House Energy and Commerce Subcommittee on Health April 26 at 10 a.m. ET is holding a <a href="https://energycommerce.house.gov/posts/chairs-rodgers-guthrie-announce-bipartisan-health-subcommittee-legislative-hearing-on-transparency-and-competition" target="_blank">legislative hearing</a> on 鈥淟owering Unaffordable Costs: Legislative Solutions to Increase Transparency and Competition in Health Care.鈥� <a href="https://energycommerce.house.gov/committees/subcommittee/health" target="_blank">View the subcommittee members.</a></p><p>The hearing is a follow-up to a hearing the subcommittee held last month on this topic. The April 26 hearing will discuss 16 bills and discussion drafts that were unveiled yesterday as part of the notice for this hearing. The proposals cover topics including site-neutral payment policies, the 340B program, price transparency, Medicaid disproportionate share hospital reductions, physician-owned hospitals, pharmacy benefit managers, among others. AHA is reviewing the proposals.</p><h3>Ways and Means Subcommittee to Discuss Tax-exempt Status</h3><p>The House Committee on Ways and Means Subcommittee on Oversight April 26 is holding a <a href="https://waysandmeans.house.gov/wp-content/uploads/2023/04/ADVISORY_OS-Subcommittee-April-26-2023.pdf" target="_blank">hearing</a> at 2 p.m. ET on tax-exempt hospitals and the community benefit standard. <a href="https://waysandmeans.house.gov/subcommittee/oversight/" target="_blank">View the subcommittee members.</a></p><h3>Education and the Workforce Subcommittee on Lowering Health Care Costs</h3><p>The House Committee on Education and the Workforce Subcommittee on Health, Employment, Labor, Pensions April 26 will host a <a href="https://edworkforce.house.gov/news/documentsingle.aspx?DocumentID=409079" target="_blank">hearing</a> at 10:15 a.m. ET to discuss 鈥淩educing Health Care Costs for working Americans and Their Families.鈥� <a href="https://edworkforce.house.gov/issues/issue/default.aspx?IssueID=43422" target="_blank">View the subcommittee members.</a></p><h3>House Appropriations Subcommittee on Provider Relief Fund and Workforce Shortages</h3><p>The House Committee on Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies April 26 is holding a <a href="https://appropriations.house.gov/legislation/hearings/oversight-hearing-provider-relief-fund-and-healthcare-workforce-shortages" target="_blank">hearing</a> at 10 a.m. ET on 鈥淧rovider Relief Fund and Healthcare Worker Shortages.鈥� <a href="https://appropriations.house.gov/subcommittees/labor-health-and-human-services-education/labor-subcommittee-members" target="_blank">View the subcommittee members.</a></p><h2>AHA Resources</h2><p>The AHA Advocacy <a href="/advocacy-issues">Action Center</a> has a number of resources that can assist you in your conversations with your representative. It鈥檚 important to share examples from your own hospital or health system as those will resonate the most with your lawmaker.</p><h3>AHA Member Resources on Committee Hot Topics</h3><ul><li><a href="/advocacy/advocacy-issues/transparency-and-competition">Transparency and Competition</a></li><li><a href="/advocacy/advocacy-issues/site-neutral-payment-proposals">Site-neutral Payment Proposals</a></li><li><a href="/advocacy/advocacy-issues/340b-drug-pricing-program">340B Drug Pricing Program</a></li><li><a href="/advocacy/advocacy-issues/physician-owned-hospitals">Physician-Owned Hospitals</a></li><li><a href="/issue-landing-page/2023-04-20-tax-exempt-status">Tax-Exempt Organizations</a></li><li><a href="/talking-points/2022-12-05-talking-points-provider-relief-fund">Provider Relief Fund</a></li><li><a href="/costsofcaring">Costs of Caring</a></li></ul><h2>Further Questions</h2><p>If you have further questions, please contact AHA at <a href="tel:1-800-424-4301">800-424-4301</a>.</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2023/04/ACT-NOW-Congress-Is-Considering-Hospital-Cuts-Tell-Them-to-Reject-Proposals-that-Could-Jeopardize-Patients-Access-to-Care.pdf" target="_blank" title="Click here to download the Action Alert: ACT NOW: Congress Is Considering Hospital Cuts; Tell Them to Reject Proposals That Could Jeopardize Patients鈥� Access to Care"><img src="/sites/default/files/inline-images/Pages-1-ACT-NOW-Congress-Is-Considering-Hospital-Cuts-Tell-Them-to-Reject-Proposals-that-Could-Jeopardize-Patients-Access-to-Care.png" data-entity-uuid="6c10679c-3f71-4f6a-b6a4-1561e2ff09c3" data-entity-type="file" alt="Action Alert: ACT NOW: Congress Is Considering Hospital Cuts; Tell Them to Reject Proposals That Could Jeopardize Patients鈥� Access to Care page 1." width="695" height="900"></a></p></div></div></div> Thu, 20 Apr 2023 15:09:26 -0500 Physician Self-Referral Law/Stark law