Health Information Management

Don’t miss your chance to comment on OPPS proposed rule

APCs Insider, August 30, 2013

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By Michelle A. Leppert, CPC

Providers still have one week left before the end of the OPPS proposed rule comment period, and given the lively discussion that occurred during this week’s Advisory Panel Meeting on Hospital Outpatient Payments (HOP Panel) in Baltimore, the provider community may want to comment to CMS about its CY 2014 proposals.

The OPPS proposed rule contains some of the most sweeping changes in OPPS history, according to Jugna Shah, MPH, president and founder of Nimitt Consulting, who attended the HOP Panel Meeting. Shah says this was the first time she’s seen so many from the provider community weigh in to tell CMS and the Panel what they think of the agency’s proposals and what they like and dislike.

Shah, along with other industry stakeholders working to conduct analyses of the proposals have struggled to replicate CMS’ rule. Step one is replicating the rule, after which hospitals could model  CMS’ proposals, says Shah. But without being able to replicate the rule, other analyses become almost a moot point.

Numerous providers, the American Hospital Association, the Provider Roundtable (a group of provider representatives from across the country whose mission is to provide meaningful comments to CMS on proposed rules), and others told the HOP Panel and CMS about their concerns with its proposals for CY 2014, their struggles with the data, and their inability to to replicate the rule. In response to comments heard, CMS uploaded a new data set Wednesday night.

This was a surprise to say the least, says John Settlemyer, assistant vice president, revenue cycle for Carolinas Healthcare System and immediate past chair of the PRT. “I do not ever recall the agency re-releasing data a week before the comment period closes.”

The new data released by CMS show a $10 increase in the payment for the proposed new E/M clinic visit APC, which is the basis from which all other rates are derived as well as  other changes that end up changing the proposed payment rates published in the new addenda. “ I appreciate the agency’s responsiveness to questions raised about the data, and their release of the updated file,” says Shah. “It is impossible at this late stage in the comment process to analyze all of the proposals, model alternatives, vet them with stakeholders, and submit a meaningful comment letter in less than one week.” 

It is unclear what will happen in the week that remains but nevertheless, providers still have time to weigh in on the following major changes which include:

  • Replacing the current 20 outpatient visit CPT® codes with three HCPCS G codes
  • Expanding packaging to include seven new categories with over 2,400 codes that will either be unconditionally or conditionally packaged
  • Replacing existing device-dependent APCs with 29 new comprehensive APCs

You still have time to provide comments to CMS on the proposals.

Visit and enter "2014 OPPS" in the search field. Select the appropriate link from the list of search results.

Look for a link called Submit Comment above the name of the document. Click on this link, input the requested information, and click Submit. This completes the process and provides a tracking number for comments.

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