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.
CMS proposed that a new HCPCS modifier be appended to every code for a service furnished in a hospital's off-campus provider-based department on both the CMS-1500 claim form for physicians' services and the UB-04 form (CMS Form 1450) for hospital outpatient services in the 2015 OPPS proposed rule. Despite many detailed comments opposing this change, no consensus emerged; therefore, CMS is moving forward with implementing a slightly modified policy.
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. It also introduced complexity adjustments with comprehensive APCs (C-APCs).
With quarterly code updates and other regulatory changes from CMS throughout the year, the chargemaster coordinator has to constantly monitor the healthcare landscape, but the final few months of the year remain the most challenging.
Editor's note: Andrea Clark-Rubinowitz, RHIA, CCS, CPCH, has more than 30 years of experience working with healthcare professionals, information systems, hospital coding, and operational and compliance training. She founded and led Healthcare Revenue Assurance Associates from 2001 to 2014. Contact her at 954-465-0968 or aclark5678@gmail.com.
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.
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.
