Health Information Management

Panel recommends hospital payment for advance care planning at summer meeting

APCs Insider, August 28, 2015

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By Steven Andrews
Many healthcare industry stakeholders, including providers, technology vendors, and payers, are working overtime right now to ensure their systems are ready for the imminent ICD-10 implementation.
But the rest of CMS’ regulatory slate, such as the annual update to the OPPS, continues and stakeholders met at CMS headquarters in Baltimore this week to provide feedback to the agency.
The Advisory Panel on Hospital Outpatient Payment (HOP), which consists of full-time employees of hospitals, hospital systems, and other Medicare providers, meets at least twice a year, and invites stakeholders to publicly submit comments regarding OPPS regulations. The panel can subsequently vote on whether to make recommendations to CMS based on those comments.
Last summer’s meeting resulted in very little action, with only one vote that ended in a tie. But this week’s meeting included more interaction between commenters and the panel, with several recommendations that could impact future policy sent to CMS.
One topic that received a lot of attention was hospital payment for advance care planning. In the 2016 Medicare Physician Fee Schedule proposed rule, CMS proposed payment for two advanced care planning CPT® codes. One is an initial code for 30 minutes of discussion on advance care planning with the second being an add-on code for each additional 30 minutes. For outpatient hospitals, the codes have been assigned status indicator N (no additional payment, payment included in line items with APCs for incidental service).
Providers at the meeting, including representatives of the Provider Roundtable (PRT), a group that attends each HOP meeting, questioned whether this was simply an oversight on the part of CMS. However, John McInnes, MD, JD, director of the Division of Outpatient Care at CMS, specified that it was intentional on the agency’s part.
These services are provided by licensed and credentialed hospital staff, in conjunction with physicians and other midlevel practitioners and hospitals should be compensated separately under the OPPS, said Jugna Shah, MPH, president and founder of Nimitt Consulting, based in Washington, D.C., and Spicer, Minnesota. Shah presented on behalf of the Alliance of Dedicated Cancer Centers.
In addition to compensating hospitals for providing these services, CMS would be able to collect detailed data on the impact of advance care planning on patient satisfaction and outcomes, Shah said.
Shah asked the panel to recommend to CMS that the initial CPT code be assigned to APC 5012 (level 2 examinations and related services) and the add-on code to be assigned to APC 5011 (level 1 examinations and related services).
After some debate, the panel voted 8-5 to recommend those changes to CMS.
Providers still have until August 31 to provide comments to CMS on advance care planning and any other proposals outlined in the 2016 OPPS proposed rule. The October issue of Briefings on APCs will feature additional coverage of the HOP meeting and the recommendations made to CMS.

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