2017 OPPS Final Rule: CMS Removes Seven Codes from Inpatient-only List

CMS removed seven codes from the inpatient-only list in the 2017 OPPS final rule, but decided not to change the designation of a code involved with several of the agency’s bundled payment models.  

Each year, CMS reviews procedures on the inpatient-only list, which consists of services typically provided on inpatients and not payable under the OPPS, to consider whether they are now being performed safely and consistently in outpatient departments.

The agency proposed to remove six procedures described by CPT codes from the list for 2017:

• 22842, posterior segmental instrumentation (e.g., pedicle fixation, dual rods with multiple hooks and sublaminar wires); three to six vertebral segments (List separately in addition to code for primary procedure)
• 22845, anterior instrumentation; two to three vertebral segments (List separately in addition to code for primary procedure)
• 22858, total disc arthroplasty (artificial disc), anterior approach, including discectomy with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); second level, cervical (List separately in addition to code for primary procedure)
• 31584, laryngoplasty; with open reduction of fracture
• 31587, laryngoplasty, cricoid split

Most commenters agreed with removing these codes from the list, and CMS also considered removing other codes based on commenter feedback. Ultimately for 2017, the agency decided to remove the six aforementioned codes, as well as CPT code 22585 (arthrodesis, anterior interbody, including disc space preparation, discectomy, osteophytectomy, and decompression of spinal cord and/or nerve roots; each additional interspace).

CMS solicited comments on removing CPT code 27447 (arthroplasty, knee, condyle and plateau; medical and lateral compartments with or without patella resurfacing [total knee arthroplasty]), which has been on the inpatient-only list since 2000, when the list was created. The agency previously proposed removing the code in 2013, but did not due to commenters asking for it to remain.

The inclusion of 27447 on the inpatient-only list has been complicated by the introduction of the Comprehensive Care for Joint Replacement (CJR) and Bundled Payment for Care Improvements (BPCI) models. The models, which bundle payment for entire episodes of care, are based on historical episode spending data, and it would become more difficult to set price targets if the procedure is removed from the inpatient-only list.

The overwhelming majority of commenters supported removing the code from the inpatient-only list, CMS said in the final rule. However, commenters also asked CMS to consider the implications of removing the code on the CJR and BPCI models, and requested modifications to the models if the procedure is removed. The agency said it would consider all comments in future policy.

For the full list of codes on the inpatient-only list, see Addendum E of the final rule.

To learn more about the changes and prepare for 2017, join Jugna Shah, MPH, president and founder of Nimitt Consulting, Inc., and Valerie Rinkle, MPA, lead regulatory specialist and instructor for HCPro, a division of BLR, in Middleton, Massachusetts, who will analyze the rule and give a comprehensive overview in HCPro’s annual OPPS final rule webinar from 1-2:30 p.m. (Eastern) Thursday, December 1.