Prepare for Potential Changes for Device-Intensive Procedures

by Jugna Shah

The 2017 OPPS final rule will not be out for a couple of weeks, but that doesn't mean providers can't be thinking about what their action plan will be once the rule is released.

With only 60 days between the final rule's release and the January 1 implementation date, providers will be ahead of the curve by spending time now and thinking about the processes they may need to review, change, or implement based on what CMS finalizes and the sort of financial impact the final rule is likely to have.

While I don't know with 100% certainty what CMS will finalize, revise, delay, or back away from, I offer providers this list of what they should look at immediately upon the rule's release. For information on dealing with Section 603 provisions of the rule, see last week's article. 

Device-intensive procedures

CMS introduced a number of changes in the 2017 OPPS proposed rule for device-intensive procedures. This is a place where we hope to see CMS finalizing changes as proposed.

For example, CMS proposes to use the implantable device cost-to-charge ratio (CCR) for calculating pass-through device payments for hospitals that file cost reports designating that cost center, as this is a more accurate CCR for determining separate pass-through payment and is a good proposal. Currently, only about two-thirds of hospitals use the implantable device CCR, which means the remaining one-third need to examine their internal cost reporting process.

Providers should check to determine whether they are in the group that reports the implantable cost center or not and if you are not reporting, find out why and begin making changes. This will have an impact on your facility’s ability to generate much better pass-through payment going forward, when applicable.

Finally, it will be interesting to see if CMS finalizes the addition of another 25 comprehensive APCs (C-APC) and if so, a financial impact analyses of these services will also be important. This is a big increase in C-APCs in one year and will require a thorough financial analysis.

I plan to discuss these and other final rule changes in my next column, as well as in HCPro’s annual OPPS final rule webcast December 1, but in the meantime I hope the above checklist will be useful to providers now and in the first weeks of the rule’s release.

Editor's note: Shah, president and founder of Nimitt Consulting, writes a bimonthly column for Briefings on APCs, commenting on the latest policies and regulations and analyzing their impact on providers.To read the full article, see the November issue of Briefings on APCs.