The policies that CMS publishes each year in the OPPS proposed rule don't always come as a surprise. Sometimes, CMS will announce its future intent in a previous rule in order to notify providers about data it is looking at or requesting comments on.
When CMS introduced the -X{EPSU} modifiers in August 2014 to be used in specific instances to replace modifier -59 (distinct procedural service), the agency encouraged "rapid migration" to the new modifiers.
CMS released updated I/OCE specifications in January with several changes that could require providers to examine claims submitted early in 2015 that include comprehensive APCs (C-APC) to ensure proper payment.
Each year, the AMA updates the Vaccines, Toxoids section of the Medicine chapter in the CPT® Manual to add or revise descriptions of newly available products. In 2015, the AMA added two new product codes (90651, 90630) and revised four (90654, 90721, 90723, and 90734).
The implementation of Comprehensive APCs (C-APCs) in the 2015 OPPS final rule likely wasn't a huge surprise to most providers, given CMS discussed this concept in the 2014 final rule and indicated it expected to implement it the following year.
The January quarterly I/OCE update includes new modifiers, changes related to expanded packaging, and continued refinement of CMS' skin substitutes categories, but the biggest change for outpatient hospitals is the implementation of comprehensive APCs (C-APC).
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.
