Olympic Medical Center is a comprehensive health care provider serving the residents of Port Angeles, Sequim and surrounding communities. Inpatient services include a level-three trauma designated emergency department, surgical services, and labor and delivery. Outpatient services include cardiac care, cancer care, diagnostic imaging, physical therapy and rehabilitation, laboratory, orthopaedics, surgical services, sleep center, home health, primary care, a walk-in clinic and specialty physician clinics.
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Protect Local Health Care!

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How to Submit Comments to CMS:

Submitting comments to CMS is easy!

In commenting, please refer to file code CMS-1695-P when commenting on the issues in this proposed rule. Because of staff and resource limitations, comments are not accepted by FAX transmission.

Comments, including mass comment submissions, must be submitted in one of the following ways:

1.    Preferred Method: Electronically. click the following link to submit electronic comments on this regulation to http://www.regulations.gov. You may input your comment directly or attach a file.

2.    By regular mail. You may mail written comments to the following address ONLY: Seema Verna, Administrator, Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1695-P, P.O. Box 8013, Baltimore, MD 21244-1850. 

Please allow sufficient time for mailed comments to be received before the close of the comment period.

What should I include in my comments to CMS?

Please consider including a few of the facts below to support your comments:

  • This proposal will limit Clallam County residents' access to health care. For OMC's off-site clinics in Sequim and Port Angeles, this is a 60% cut in physician clinic expense reimbursement. CMS is proposing to cut $3.4 million in 2019 in reimbursement for local clinics that provide needed services.

  • Clallam County’s economy will be harmed. Site neutral payment cuts of $47 million over the next decade, if implemented, will result in fewer jobs and fewer health care services for Clallam County citizens. Our future economic development depends on having a healthcare delivery system that can grow with our population and meet healthcare needs adequately. OMC is the largest employer in Clallam County with more than 1,500 employees and we need to continue to grow to help fill healthcare shortages.

  • Clallam County has a shortage of health professionals which will be made worse by this rule. In Clallam County, we lack needed physicians, registered nurses, physical therapists, medical assistants and other medical professionals. These large cuts will hurt OMC’s ability to recruit and retain the workforce to provide excellent care to our patients and to deliver value to the Medicare program.

  • Clallam County healthcare services need to be expanded, not limited.  CMS proposes to cut reimbursement by 60% for new services at previously grandfathered clinics. This restricts rural and safety net hospitals from adding services in the future. 

  • With less primary care access, visits to the Emergency Department will increase. Site neutral policies will result in less primary and preventive care, and more emergency department and hospital utilization. CMS will deprive our community of needed resources to invest in wellness, prevention and chronic disease management services, all which help reduce and prevent emergency department and hospital utilization.

  • OMC is also the only provider of most clinic services in Clallam County. OMC has supported outpatient clinic services – particularly in the last 15 years – in an effort to ensure the care is available locally.

  • The idea of site neutral does not work in rural communities where there are no independent physicians because long ago they determined they could not afford to operate at such a low reimbursement.

  • In regards to payer mix, our hospital has the highest percentage of Medicare in Washington State that is NOT a critical access hospital. Medicare is 60% of our business, and Medicaid and Tricare covered constituents brings us up to 83% government payers!

  • There are no independent primary care and specialty clinics in the area to step in if OMC must cut services.

  • Hospital-based payment allows safety-net hospitals to provide preventive services and chronic care management to vulnerable populations, keeping them out of the hospital and out of expensive emergency rooms. Hospital outpatient departments and clinics are a vital part of caring for an underserved population!

  • CMS is showing a lack of understanding about the reality in which hospitals – particularly rural hospitals – operate daily to serve the needs of their communities. Without hospital-based clinics, rural communities like Sequim would not have access to the health care services they need or they would have much higher cost critical access hospital models.

  • Congress was clear that grandfathered facilities were not to have their payments reduced. The cuts to grandfathered off-campus clinics in this rule goes too far, and we want to ensure these clinics continue to be protected from site-neutral cuts.

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