Health Information Management

HOP Panel concludes with little fanfare despite major OPPS proposals

APCs Insider, August 29, 2014

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By Steven Andrews, Editor
 
Proposed changes to the OPPS next year—from Comprehensive APCs to greatly expanded packaging—should have providers eager to take every possible opportunity to comment in front of CMS on the potential financial and operational implications for their facilities.
 
But the summer meeting of the Advisory Panel on Hospital Outpatient Payment (HOP) Monday at CMS included little provider commentary or presentations, and ended with no insight into recommendations the panel will make to CMS regarding the OPPS final rule.
 
The meeting, held at least twice a year, invites stakeholders to publicly submit comments regarding OPPS regulations in front of a panel that consists of a broad variety of providers and administrators. The panel can subsequently vote on whether to make recommendations to CMS based on those comments.
 
This year’s summer meeting was only half a day, compared to a day and a half in August 2014, when CMS proposed collapsing all E/M levels into three HCPCS G codes. John McInnes, MD, JD, director of the Division of Outpatient Care at CMS, noted during the meeting that the 2015 OPPS proposed rule “didn’t register as high on the Richter scale” for providers.
 
In fact, most of the public presentations came from medical device and pharmaceutical representatives regarding proposed changes to their specific products.
 
The panel only voted on one individual issue, the continued debate about supervision levels for certain chemotherapy administrations. At the March 2014 HOP meeting, the panel recommended changing the supervision level of eight chemotherapy HCPCS codes from direct to general. CMS responded that it thought the levels were appropriate as direct, asking providers to comment and the panel to further deliberate at the August meeting.
 
This was one of the few topics that included provider input during the meeting. Several critical access hospital (CAH) representatives submitted written comments to the panel and appeared at the meeting to ask CMS to change these services to general supervision, due to the difficulty of having providers immediately available to provide direct supervision in CAHs.
 
The panel voted on whether to recommend direct supervision for initial administrations, while allowing general supervision for subsequent administrations, but tied 6-6. They did not vote on any other stakeholder proposals individually. At the end of the meeting, the panel voted collectively on the other presentations, choosing to make no recommendations to CMS on them.
 
The lack of provider input is partially due to the tight schedule between the release of the OPPS proposed rule and the deadline for submitting presentations for the summer meeting, leaving little time to run data on each proposal to determine the financial impact.
 
While they did not make any public presentations, the members of the Provider Roundtable (PRT), which attends each HOP meeting, were at CMS to comment on several of the issues the panel considered. The PRT met throughout the week to discuss further comments to submit to CMS regarding specific OPPS proposals.  
 
Any recommendations the panels makes to CMS will be posted on the CMS website. Comments on the 2015 OPPS proposed rule are due to CMS by September 2.



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