providers, but CMS is trying to push these hospital facilities to become
as efficient and low-priced as independent physicians and ASCs," says
Michele Molden, MBA, FACHE, of the Advisory Board, a Washington,
D.C., consulting firm.
Site neutrality also could slow ASC-to-HOPD conversions, says Kara
Newbury, JD, regulatory counsel for the Ambulatory Surgery Center
Association (ASCA), as hospitals would have less incentive to acquire
ASCs and confer upon them HOPD status to secure the higher Medicare
rates paid for outpatient services performed in hospital-owned surgical
centers. (Of the 285 ASCs that left the Medicare system from 2009
through 2013, at least 101 were converted to HOPDs, says ASCA.)
Physicians, who'll be paid for procedures at off-campus sites at the
non-facility Medicare Physician Fee Schedule (MPFS) rates, should
reassign their billing rights to the hospital so it can submit claims to
Medicare on their behalf and collect its portion of the payment to
cover facility fees, says Cheryl Storey, CPA, a partner in the Moss
Adams healthcare group.
One notable exemption to site neutrality: HOPDs that were billing
under OPPS as of Nov. 2, 2015, will continue receiving payments
under OPPS for those services after Jan. 1, 2017.
GI moderate sedation. CMS is proposing to separate moderate
sedation from GI endoscopy procedure codes to prevent paying
endoscopists for sedating patients even when an anesthesia provider
is present and billing CMS separately. Under this change, the value of
moderate sedation would be backed out of the current value of the
code and moderate sedation would be reported and paid separately
when performed. For GI docs providing their own moderate sedation,
there would be no financial impact, says the American
Gastroenterological Association. Instead, these physicians will report
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