Medical Coding And Billing
Ambulatory Surgical Center Payment System Rule

CMS has released their final rule for 2017 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System. This rule implements site neutral payment options for the Bipartisan Budget Act of 2015.

It is reported that CMS is implementing Section 603 of the Bipartisan Budget Act of 2015. Under the section, some of the off-campus provider-based departments that started billing under Outpatient Prospective Payment System on or after Nov 2, 2015, will not be paid for most of the services under OPPS. Instead of that, from Jan 1, 2017, the payments to these health facilities will be made under physician fee schedule. However, the services that are offered in a dedicated emergency department will be paid under OPPS.

Under the final rule, CMS has also made some restrictions on off-campus PBDs that started billing under OPPS before Nov2, 2015. CMS has finalized a proposal that needs the departments to provide bills and services from the same address as they did on Nov 2, 2015, if they wish to be exempted from site-neutral payment provisions. Exceptions will be made for the off-campus PBDs that are forced to permanently or temporarily relocate owing to unforeseen causes, like a natural disaster.

In the month of July, CMS proposed the off-campus PBDs to offer the same services as they did earlier, and these off-campus PBDs will be excluded from site-neutral payment provisions; although the proposal is not yet finalized by the agency. “CMS will monitor expansion of clinical service lines by off-campus PBDs and continue to consider whether a potential limitation on service line expansion should be adopted in the future,” a representative said.

However, CMS said that they are finalizing some of the proposals. For example, the agency is still working on a proposal that allow off-campus PBDs to maintain excepted status, if the facility is sold and the new owner of the facility accepts the existing Medicare provider agreement.

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Hospital Outpatient Prospective Payment System

Interestingly, the American Hospital Association is satisfied with some of the changes that CMS has made. “We appreciate the modifications CMS made to its proposal to allow existing hospital clinics to expand their services to meet the changing needs of their patients and communities without being penalized,” said Tom Nickels, who is the executive vice president of government relations and public policy at the AHA.

“However, we are alarmed that CMS continues to ignore the need for hospitals to modernize existing facilities so that they can provide the most up-to-date, high-quality services to their patients. We continue to be concerned that such ‘site-neutral’ policies and CMS’s implementation of them could impede patients’ access to care, especially in the most vulnerable communities. We are evaluating the details of the final rule and will provide further comment to CMS,” he added.

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