WHITE PAPER
Read the White Paper
Site-neutral payments refer to policies designed to equalize reimbursement rates for healthcare services regardless of the care setting. In other words, the same service would receive the same Medicare reimbursement whether performed in a hospital outpatient department (HOPD), physician’s office, or ambulatory surgery center (ASC).
Proponents argue that site-neutral payments eliminate payment discrepancies, lower overall healthcare costs, and create a more efficient healthcare market. Critics, however, contend that site neutrality could financially strain hospitals, reduce care quality, and limit healthcare accessibility in rural areas.
This paper provides a comprehensive analysis of site-neutral payments, examining their history, regulatory landscape, key arguments for and against the policy, and the broader implications for healthcare stakeholders, including patients, providers, and investors.

Douglas Hervey
Partner
Douglas Hervey is a partner at Cicero Group with an emphasis in healthcare and private equity services. Douglas most recently worked as a senior director for Leavitt Partners. As a senior director, Douglas enabled healthcare entities to more effectively aggregate data, automate research processes, and make sound growth-oriented strategic and investment decisions. He has worked on over 200 healthcare private equity investment deals, within 80 unique healthcare sub-segments, for over 40 investment funds.
Douglas earned his bachelor’s degree in international relations at Brigham Young University, after which he earned his juris doctorate from the University of Pittsburgh. Douglas also holds an MBA from Brigham Young University, where he was a Hawes Scholar.

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