On January 12, 2012, the Medicare Payment Advisory Commission (MedPAC) recommended that reimbursement to hospital outpatient departments (HOPDs) for evaluation and management (E&M) services be reduced to equal payment for E&M services under the physician fee schedule (PFS). According to MedPAC, hospitals have been increasing employment of physicians, and services likely will shift from free-standing practices to HOPDs. Since the hospital outpatient prospective payment system (OPPS) rates are typically much higher than the PFS rates, this shift would result in increased program spending and beneficiary cost sharing....

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