Revenue Cycle

New OPPS proposed rule pushes wholesale packaging: CMS takes initial steps toward paying for encounters, not services

Patient Financial Services Weekly Advisor, July 20, 2007

The outpatient prospective payment system (OPPS) has seen its fair share of changes every year since its inception in 2000. But for 2008, CMS is proposing perhaps its most drastic change yet: Wholesale packaging.

CMS is "proposing to view a service, in some cases, as not just the diagnostic or treatment modality identified by one individual HCPCS code but as the totality of care provided in a hospital outpatient encounter that would be reported with two or more HCPCS codes for component services," according to the 2008 OPPS proposed rule, released Monday.

This means that many services for which hospitals currently receive separate payment-e.g., observation, many imaging supervision and interpretation services, and diagnostic radiopharmaceuticals, among others-will no longer receive separate payment in 2008, according to CMS' proposal.

Specifically, CMS proposed to package the payment for HCPCS codes describing the dependent items and services in the following seven categories into the payment for the independent services with which they are furnished:

  • Guidance services
  • Image processing services
  • Intraoperative services
  • Imaging supervision and interpretation services
  • Diagnostic radiopharmaceuticals
  • Contrast media
  • Observation services

    CMS is proposing to roll the payment for these services into the main procedure and/or visit code associated with the patient's visit. For example, rather than paying observation code G0378 separately (APC 0339, national average payment of $442.31) in addition to level five emergency department E/M code 99285 ($325.26), CMS will pay only for 99285, albeit at a slightly higher rate ($348.81) to reflect the packaging of G0378.

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