The healthcare financial management association hfma would like to thank the centers for medicare medicaid services cms for the opportunity to comment on the medicare program proposed changes to hospital outpatient prospective payment and ambulatory surgical center payment systems and quality. However a comprehensive strategy is needed to manage an organizations outpatient care portfolio without such an approach providers inadvertently may take on unexpected financial risks as a shift to outpatient care can increase costs and lead to lower revenue reducing the benefits of shifting care away from inpatient services
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