Health Information Management

CMS releases 2014 OPPS Proposed Rule

HIM-HIPAA Insider, July 15, 2013

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by Jaclyn Fitzgerald, Online editor 

CMS released the 2014 OPPS Proposed Rule June 8. The proposed changes could significantly impact hospital evaluation and management (E/M) coding and reimbursement and packaged services in particular.

The proposed rule could result in the elimination of the five levels of E/M CPT® codes for new patient clinic visits, established patient clinic visits, and Type A ED visits, and HCPCS G-codes for Type B ED visits. These codes would be replaced with three new HCPCS G-codes, including one APC for all clinic visits, one for all Type A ED visits, and one for all Type B ED visits.

Like anything else, this standardized means of coding has its pros and cons. According to Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS, director of coding and HIM at HCPro, the proposed changes to technical E/M services could lead to a fewer instances of over-reporting and under-reporting. However, it could be met with adversity if the payments associated with these codes are not “budget neutral,” she says.

If the E/M proposed changes are finalized, the same APC would be paid out regardless of the nature of a clinic or the resources used. Reimbursement issues would likely be more of a cause for concern in the ED than in clinics, because of variations in the level of care and length of time spent with ED patients, says Kimberly Anderwood Hoy, JD, CPC, director of Medicare and compliance at HCPro.

Proposed changes in the packaging of services are also making waves. CMS proposed seven new categories for packaging of items and services. Addendum P lists 2,149 codes that were proposed for this packaging. This includes the never-before-seen packaging of laboratory tests as well as add-on drug administration codes for additional hours, injections, infusions, etc. At first glance, it appears that the proposed packaging could increase procedure APC rates but each facility will need to perform an analysis to grasp how this will affect their finances, says Jugna Shah, MPH, president and founder of Nimitt Consulting.

The 2014 OPPS Proposed Rule will be featured in the Federal Register July 19, and in the meantime there is a downloadable copy available. CMS welcomes healthcare providers to submit comments for inclusion in the final rule, which will be issued by November 1. All comments must be submitted by September 6.

Read more about the proposed rule on the HCPro website.

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