Health Information Management

Comment period on OPPS proposed rule ends Sept. 14, so prepare your comments now

APCs Insider, August 17, 2007

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QUESTION:  The 2008 OPPS proposed rule seems very detailed and lengthy. What would you recommend that we should read? I know that the comment period ends on Sept. 14.
ANSWER: The length of this year's OPPS proposed rule can be difficult to manage, so we provided a list of six major changes, including page number references, so you can find the original discussion. You can also download an easier to read Federal Register version of the rule from the CMS Web site: To learn how to submit comments, see p. 2 of this version.

The six major changes include the following:

  1. Proposed extensive changes to packaged services to include seven categories--guidance, imaging processing, intraoperative, image supervision and interpretation services, radiopharmaceuticals, contrast agents, and observation services. Many services that had payable status indicators (SI) are changing to SI "N" or SI "Q" with special grouping for SI "T," "V," "X," and "S" (p. 42648).
  2. Introduction of composite APCs. These include prostate brachytherapy and cardiac EPS/ablation. Note that prostate brachytherapy seeds are moving to payable APCs as opposed to being paid based on cost (p. 42677).
  3. Separately payable drugs in the OPPS system moving from average sales price (ASP) + 6 % to ASP + 5%, plus a new, higher threshold for packaged drugs ($60) (p. 42731).
  4. Capturing drug acquisition charges separately with a new revenue code (p. 42735).
  5. Facility E/M levels discussion with proposed visit reporting guidelines that CMS will maintain (p. 42751).
  6. Ambulatory Surgery Center (ASC) revised payment system and the increased number of surgical procedures that can be performed in the ASC setting beginning in 2008. Ask yourself what impact this will have on your hospital surgical services. (You can find this discussion throughout the rule).

We urge all facilities to appoint a designated person or people to read the rule and comment on the impending changes and updates. Work with your internal team, or better yet, work through your hospital associations to ensure that CMS hears your opinions and comments loud and clear.

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