From the August 2015 issue of HealthCare Business News magazine
On July 1, 2015, the Centers for Medicare and Medicaid Services (CMS) released their proposed rule for CY 2016 for Hospital Outpatient Departments (OPPS) and Ambulatory Surgical Centers Prospective Payment Systems.
With this proposed rule, CMS projects total OPPS payments to decrease by 0.1 percent in CY 2016. The proposed decrease in payment rates is based on adjustments to the payment update to redress the excessive packaging of services in 2014, particular lab services, and other policy changes as required by law.
After considering all other policy changes proposed under the OPPS, including estimated spending for pass-through payments, CMS estimates that total payments for the approximately 3,800 hospitals and 60 CMHCs paid under the OPPS would decrease by $43 million in CY 2016 compared to CY 2015 payments.
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Also, hospitals failing to meet the hospital outpatient quality reporting program in 2014 would be subject to a 2 percent reduction on their 2016 payments. Comments will be accepted by CMS on this proposed rule if submitted by Aug. 31, 2015. This proposed rule is of interest to the imaging community for several reasons.
First, it proposes a re-organization of the Ambulatory Payment Classifications (APCs) for imaging services that reduces the overall number of payment categories. For some services this means large increases, and it also means, for others, fairly large decreases. Depending on what imaging services your hospital outpatient department focuses on, this could be a winning proposal or it could be of concern.
The 60-day comment period gives all stakeholders the opportunity to evaluate the proposed reconfiguration and decide if there are better ways to do what CMS is attempting, and send that in to CMS. In proposing an APC reconfiguration for hospital outpatient department payments for imaging services, CMS states that the current level of granularity in some of the imaging APCs is unnecessarily narrow for the purposes of a prospective payment system.
CMS specifically called out the current APCs for X-ray and nuclear medicine services as supporting this rationale. Therefore, CMS is proposing to consolidate the APCs for radiology and nuclear medicine services, with the proposed new APCs only being differentiated by type of modality and whether or not contrast was used during the imaging procedure.
The resources used to perform the procedure, as represented by hospital submitted claims data, would be used to determine what level of APC the procedure would be assigned to. Another area that was of concern to the imaging community last year was the expanded “packaging or bundling” proposal that CMS finalized, whereby certain imaging APCs, where the geometric mean for the APC was less than $100, would be packaged or not pay separately when those services were performed with a surgical procedure on the same day.