Health Information Management

CMS seeks comments on HCPCS modifier for data collection

APCs Insider, August 8, 2014

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By Steven Andrews, Editor
 
One of CMS' proposals in the 2015 OPPS proposed rule won't immediately impact patient care or hospital payments, but could create a hefty administrative burden for providers.
 
CMS proposes to create a HCPCS modifier to be reported with every code for physician and outpatient hospital services furnished in off-campus provider-based departments beginning January 1, 2015. The modifier would have to be reported on both the CMS-1500 claim form and the UB-04 form.
 
According to CMS:
We believe it is important to develop an understanding of which practice expense costs typically are incurred by the physicians and practitioners in the setting, which are incurred by the hospital, and whether the facility and nonfacility site of service differentials adequately account for the typical resource costs given these new ownership arrangements.
 
This request shouldn't come as a surprise to providers. The disparity in payment rates for some services in provider-based clinics compared to freestanding clinics has been a frequent concern for the Medicare Payment Advisory Commission (MedPAC) and OIG. By collecting this data, CMS would be able to more accurately adjust OPPS and Medicare Physician Fee Schedule payment rates to reflect costs to physicians and facilities.
 
CMS also raised the possibility of collecting data on off-campus provider-based services in the 2014 OPPS proposed and final rules, citing the trend toward hospitals acquiring physician practices as well as MedPAC concerns.
 
CMS also proposed creating a new place of service code to be reported on CMS-1500 claim forms when physician services are furnished in an off-campus provider-based department, in last year's OPPS proposed rule.
 
However, CMS noted in the 2014 OPPS final rule that despite commenter support for collecting this data, no consensus was reached on the least burdensome method for doing so. With CMS once again specifically asking for comments, and continued OIG and MedPAC pressure, it's likely the final rule will introduce some method for collecting this data.
 
Providers should read CMS' proposal in the current rule, as well as its response to last year's comments, in order to determine which method makes the most sense for their facility. CMS offers several avenues for submitting comments, which are due by September 2.
 
To learn more about the 2014 OPPS proposed rule and what changes may be coming in 2015, join Jugna Shah, MPH, and Valerie A. Rinkle, MPA, for HCPro's annual OPPS proposed rule webcast August 13.



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