Competition and Transparency - Payment Reforms

Large employers strongly support site-neutral payment reforms because they help eliminate artificial price differences for the same services delivered in different settings—such as hospital outpatient departments versus independent physician offices. These outdated payment disparities not only inflate costs, but also incentivize hospital consolidation and drive care into higher-cost settings. ERIC and other employer coalitions have consistently urged Congress to adopt site-neutral policies, as reflected in multiple stakeholder letters and advocacy efforts tied to the Lower Costs, More Transparency Act and broader health care reform. By aligning payments with the actual value of services—regardless of location—these reforms promote fairness, reduce unnecessary spending, and restore competitive pressure in the health care marketplace.

  • Fair Billing Act (S. 2497)
    • The bill would require each off-campus, outpatient department of a provider to bill using a unique provider identifier to foster more honest billing practices by providers. This language is identical to the bipartisan, bicameral negotiated text from the draft December 2024 health package. ERIC supports the measure and continues to advocate for Congress to take up the December 2024 health package by the end of this year. The press release include a quote from ERIC’s President and CEO James Gelfand applauding Senators Maggie Hassan (D-NH) and Roger Marshall (R-KS) for introducing their legislation that would bring much needed transparency and accountability to the shell games hospitals are playing.
  • Site Neutral Payments
    • Alliance For Fair Health Pricing OPPS Comments and Statement
      • The Alliance for Fair Health Pricing (AFFHP), a nonpartisan coalition of consumers, patients, and employers committed to making health care more affordable, submitted comments on the Changes to the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems 2026 Proposed Rule supporting the implementation of site-neutral payment reforms for drug administration. The Center for Medicare and Medicaid Services (CMS) finalized the site-neutral drug administration policy in the 2026 Outpatient Prospective Payment System (OPPS) rule, which represents progress on site-neutral payment reforms.
    • Alliance For Fair Health Pricing Site Neutral Hill Letter
      • This letter to congressional leadership highlighted concerns on health care affordability and urged for Congress to consider passing policies such as site of service billing transparency and site-neutral payment reforms.
    • Stakeholder Letter to Congress on Site Neutral Payment
      • ERIC and 28 other organizations called on Congress to advance site-neutral payment and billing transparency reforms.
    • SITE Act Letter from Third Way and Progressive Policy Institute
      • Third Way and Progressive Policy Institute organized a letter with ERIC and 23 other organizations encouraging Senators Ron Wyden (D-OR) and Mike Crapo (R-ID) to act on the Site-based Invoicing and Transparency Enhancement (SITE) Act.
    • Site Neutral Hill Letter with Stakeholders
      • ERIC and eight other organizations representing patients, consumers, employers, and physicians urged congressional leadership to advance legislation to promote site-neutral payments and site-of-service billing transparency
    • Stakeholder Letter on Site Neutral Policies
      • ERIC and eight other organizations representing patients, consumers, employers, and physicians urged congressional leadership to promote site-neutral payments and site-of-service billing transparency in a way that protects access to care
    • Alliance for Fair Health Pricing Site Neutral Budget Joint Letter
      • ERIC and seven other organizations urged congressional leadership to advance comprehensive site-neutral payment reform in Medicare
  • Site Neutral in LCMTA