CODING & BILLING
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service under the OPPS. In the OPPS rule, CMS created
Comprehensive-APCs to prospectively provide a single payment for
the entire hospital stay for high-cost, device-dependent services in 29
device-dependent APCs.
CMS is proposing "additional Comprehensive-APCs, including some
lower cost, device-dependent APCs that were not proposed in 2014,
and two new APCs for other procedures and technologies that are
either largely device-dependent or represent single session services
with multiple components." CMS also proposes to restructure and
consolidate some of the current device-dependent APCs with similar
costs using 2013 claims data. After all of the restructuring, there are
28 Comprehensive-APCs proposed in the 2015 rule as compared to
the 29 that were finalized last year. CMS is not proposing to use these
Comprehensive-APCs for ASC payments, which means that certain
procedures would still be separately payable in the ASC setting in
2015 but not the HOPD setting. It is unclear at this point the extent to
which the Comprehensive-APC policy will impact ASCs, but it is
something to monitor.
Expanded packaging of codes.
CMS currently pays HOPDs and
ASCs separately for services that are integral to a primary serv-
ice. For 2015, CMS is proposing to conditionally package ancil-
lary services assigned to APCs with a geometric mean cost of $100 or less
(before applying the conditional packaging status indicator to the servic-
es within these APCs) as a criterion to establish an initial set of condition-
ally packaged ancillary service APCs. Conditional packaging means that
if these ancillary services are furnished by themselves, CMS will continue
to make separate payment for the service.
