Fortunately for providers, CMS decided not to cap outpatient payment rates for cardiac resynchronization therapy defibrillator (CRT-D) procedures at the standardized inpatient rate. The agency announced its decision as part of the CY 2012 OPPS final rule released November 1, 2011.
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 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.
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.
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.
The July quarterly I/OCE update from CMS brought few new APCs or edit updates, but did deliver new modifier -L1. Hospitals will use the new modifier to submit outpatient laboratory tests paid under the Clinical Laboratory Fee Schedule (CLFS) in certain circumstances to claim separate payment.
Hospital outpatient therapeutic services, such as ED or clinic visits, that are paid under the OPPS or to critical access hospitals (CAH) on a cost basis must be furnished "incident to" a physician's service to be covered.
The January 2014 quarterly I/OCE update included nearly 400 new HCPCS Level II codes, but the most significant changes for providers may center on relatively few codes, as a result of modifications CMS made in the 2014 OPPS final rule.
CMS has been making it clear over the years that packaging would become a larger and larger part of OPPS, and in calendar year (CY) 2014 CMS made good on this.
