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A U G U S T 2 0 1 4 | O U T P AT I E N T S U R G E R Y M A G A Z I N E O N L I N E
CODING & BILLING
Device-intensive policy change.
CMS also makes a positive
change to its device-intensive policy in the proposed rule,
proposing to define ASC device-intensive procedures as
those procedures that are assigned to any Ambulatory Payment
Classification (APC) — not only an APC formerly designated device-
dependent — with a device offset percentage greater than 40% based
on the standard OPPS (Hospital Outpatient Prospective Payment
System) APC rate-setting methodology. The previous threshold was
50%, and ASCA has advocated strongly for a lower threshold.
Medicare could realize substantial savings if the ASC payment were
adequate to cover the cost of expensive implants and supplies. But
more than 150 codes for procedures currently considered device-
intensive are rarely performed in ASCs but are often performed in the
HOPD setting (stent placement codes 37221 and 37226, for example).
These procedures don't qualify for device pass-through payments
when performed in ASCs. Even though the cost of the device is
greater than 50% of the cost of the procedure in the ASC setting, the
device cost doesn't meet the 50% threshold in the HOPD setting.
ASCA recommends that CMS establish a threshold at 30% of the OPPS
rate, which is equivalent to 50% of the ASC rate.
OPPS comprehensive APC policy.
Although the OPPS is named
such because it's supposed to be a prospective payment sys-
tem, it's currently closer to a fee-for-service system, such as
the one seen in the physician fee schedule. To make the OPPS more
consistent with a prospective payment system, CMS adopted a
Comprehensive-APC policy in the 2014 final payment rule but delayed
implementation of this policy until 2015 to allow for more public com-
ment. This policy would expand the categories of related items and
services packaged into a single payment for a comprehensive primary
