The 2016 OPPS proposed rule is likely to continue CMS' trend of expanded packaging and feature refinements and expansion of comprehensive APCs based on comments CMS has made in prior rules.
In a concerted effort to move healthcare payments to a system of "quality over quantity," CMS finalized policies that greatly expanded packaging for outpatient providers in the 2015 OPPS final rule (www.gpo.gov/fdsys/pkg/FR-2014-11-10/pdf/2014-26146.pdf). It also introduced complexity adjustments with comprehensive ambulatory payment classifications (C-APCs).
In December 2014, CMS posted a document on its Advisory Panel on Hospital Outpatient Payment (HOP Panel) website outlining the hospital outpatient therapeutic services that were recently evaluated for a change in supervision levels. The three-page document contains a chart that includes the HCPCS code, the level of supervision required for coverage, and the effective dates of the changes for various services.
As CMS pushes the OPPS from a fee-for-service program toward more of a true prospective payment system, financial impact analysis of changes, departmental budgeting, and forecasting has become more complicated each year.
