Health Information Management

Determine the true financial impact of CMS’ packaging proposals

APCs Insider, August 1, 2014

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Providers probably weren't surprised that CMS continued its push to increase packaging in the 2015 OPPS proposed rule, but they may have to do extensive analysis to understand the true financial impact of the proposals.
CMS' proposals include:
  • Conditionally packaging ancillary services that have a geometric mean cost of less than or equal to $100 (with some exceptions, including preventive service, counseling/psychiatry, and drug administration services).
  • Packaging add-on codes assigned to device-dependent APCs (paid separately in 2014) starting in 2015, since these device-dependent add-on codes will be paid under the Comprehensive APC policy.
  • Eliminating status indicator X (ancillary services). 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). Ancillary services with status indicator Q1 will not generate separate payment when provided on the same date of service as another separately payable procedure with a status indicator of S, T (significant procedure, multiple reduction applies), or V (clinic or ED visit. They will generate separate payment if provided on their own.
  • Packaging and changing the status indicator from 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. If this proposed change is finalized, all medical and surgical supplies would be packaged in OPPS, as happened with all non-prosthetic DMEPOS supplies for 2014.
The packaging of ancillary services with a dollar threshold isn't as clear-cut as it might sound. Providers may be surprised at the number of services CMS is planning to package in addition to status indicator X when comparing the latest Addendum B with the version included in the proposed rule.
"The proposed CPT® codes being packaged include dozens of status indicator S and T services," says Jugna Shah, MPH, president and founder of Nimitt Consulting. "These are what we usually think of as significant procedures, though CMS says some of these are really ancillary-type services."
The proposed rule's Addendum B includes more than 100 CPT codes with a status indicator S or T today that would change to Q1.
Providers should determine the financial impact these changes could have by looking at how often they report these services today, and how often they report the services alone versus with other services or procedures. Then look at the changes in rates for these services, and those they're most often provided with, in the proposed rule.
To learn more about these changes, and how to provide comments to CMS on them, join Shah and Valerie A. Rinkle, MPA, for HCPro's annual OPPS proposed rule webcast August 13.

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