CMS wants your thoughts on the 2015 OPPS proposed rule changes. In various places in the proposed rule, CMS specifically asks providers to comment on the proposals. You may submit comments to the agency until September 2.
CMS refined and updated its Comprehensive APC policy in the 2015 OPPS proposed rule released July 3, adding a new complexity adjustment factor. CMS also proposes significantly expanding the packaging of ancillary services. Additionally, the proposed rule includes a significant change to requirements related to inpatient physician certification.
When CMS releases rules, the length can be intimidating. But even at a relatively slim 700 pages, the 2015 OPPS proposed rule isn't able to include details on each of the changes CMS is planning. This is probably a good thing?otherwise the rules could be thousands of pages long. Updates like codes being moved around or status indicators changing often aren't described in full in the narrative text, necessitating a deeper look at the addenda CMS releases as Excel® files on its website.
Modifier -25 (significant, separately identifiable E/M service by the same physician on the day of a procedure) is used to distinguish visits from procedures on the same day.
It is not used to distinguish observation from a visit service on the same day.
