Health Information Management

CMS releases 2015 OPPS proposed rule

HIM-HIPAA Insider, July 14, 2014

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by Jaclyn Fitzgerald, Editor

CMS recently released its 2015 OPPS proposed rule, which includes proposed changes to the Comprehensive APC policy, packaging of ancillary services, and inpatient certification.
CMS finalized details regarding Comprehensive APCs for device-dependent APCs when it released the 2014 OPPS final rule. This year, CMS proposed consolidating and restructuring the policy to include 28 Comprehensive APCs for 2015. The most significant change is a proposed “complexity adjustment,” which would be applied when a primary procedure assigned to a Comprehensive APC is reported with other specified procedures also assigned to Comprehensive APCs or with a specified packaged add-on code. CMS would increase the payable APC to the next higher APC in the clinical group when a facility reported one of these combinations. 
CMS proposed a requirement that facilities report any medical device C code currently listed among the device edits for 2014 device-dependent APCs instead of reporting a particular device C code(s). The rule also includes proposals that would change packaging, including:
  • Packaging add-on codes assigned to device-dependent APCs
  • Conditionally packaging ancillary services with a geometric mean cost of less than or equal to $100 with exceptions
  • Eliminating status indicator X (ancillary services), which would mean that all CPT® codes currently assigned to status indicator X will either be reassigned to status indicator Q1 (conditionally packaged) or S (significant procedure, not discounted)
  • Packaging and changing status indicator A (services furnished to a hospital outpatient paid under a fee schedule or payment system other than OPPS) to N (items and services packaged into APC rates) for all DMEPOS prosthetic supplies
CMS also proposed to eliminate the inpatient certification requirement set forth in the 2014 IPPS final rule except for stays of 20 days or more and outlier cases.
CMS will accept comments on the proposed rule until September 2, 2014, and will respond to comments in a final rule to be issued on or around November 1, 2014. The proposed rule will appear in the July 14 issue of the Federal Register.
For more information about the 2015 OPPS proposed rule, visit the HCPro website or join us at 1 p.m. (Eastern) Wednesday August 13, for the live 90-minute webcast 2015 OPPS Proposed Rule: Analyze the Impact and Manage the Changes, presented by expert speakers Jugna Shah, MPH, and Valerie A. Rinkle, MPA. The program will analyze the proposed rule and deliver a comprehensive program to update you on the major changes proposed for 2015 under OPPS. When you understand where CMS is headed in 2015, you'll be in a position to plan your own internal education and process changes.

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