2017 OPPS proposed rule: CMS revises status and comment indicators

CMS has proposed several changes for status and comment indicators in the 2017 OPPS proposed rule in an attempt to better identify codes and services for providers.

CMS is proposing to replace status indicator E (services not paid, non-allowed item or service) with two more specific status indicators. The agency proposes status indicator E1 for items and services not covered by Medicare and E2 for items and services for which pricing information or claims data are not available.

CMS proposes using four comment indicators for 2017, carrying over three already in effect:

• CH, active HCPCS code in current and next calendar year, status indicator and/or APC assignment has changed; or active HCPCS code that will be discontinued at the end of the current calendar year
• NI, new code for the next calendar year or existing code with substantial revision to its code descriptor in the next calendar year as compared to current calendar year, interim APC assignment; comments will be accepted on the interim APC assignment for the new code
• NP, new code for the next calendar year or existing code with substantial revision to its code descriptor in the next calendar year as compared to current calendar year proposed APC assignment; comments will be accepted on the proposed APC assignment for the new code

To help providers identify new HCPCS codes that will have a final payment assignment for 2017 in the OPPS final rule, CMS proposes the following comment indicator:

• NC, new code for the next calendar year or existing code with substantial revision to its code descriptor in the next calendar year as compared to current calendar year for which we requested comments in the proposed rule, final APC assignment; comments will not be accepted on the final APC assignment for the new code.

For more information on comment indicators, see Addendum D2 of the proposed rule.

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, will analyze the rule and give a comprehensive overview of the changes and what providers may want to comment on—including new regulations for off-campus, provider-based locations—in HCPro’s annual OPPS proposed rule webcast from 1-3 p.m. (Eastern) Wednesday, August 17.