2 codes instead of 1 — the procedural code and the proposed moder-
ate sedation code (GMMM1). For GI doctors using an anesthesia
provider, there would be a slight payment reduction. Anesthetists pro-
viding moderate sedation for GI patients will continue to receive sepa-
rate reimbursements for their work.
Slightly higher rates. Medicare payments would increase 1.2%
to ASCs and 1.6% to hospitals under CMS's proposed ASC Fee
Schedule and Hospital Outpatient Prospective Payment System
(OPPS). These percentages don't take into account a 2% mandatory
payment reduction specified in the sequestration, which is in effect
until 2024 or until Congress acts.
Separate inflation indices to update payments. CMS plans to con-
tinue using the CPI-U (together with the multi-factor productivi-
ty adjustment) to update the ASC conversion factor while using the
hospital market basket index (together with statutory adjustments) to
update the OPPS conversion factor. Continuing to use the CPI-U for
ASCs furthers the disparity in the payment rates in the different set-
tings, says ASCA.
Device-intensive codes. Historically, codes in the ASC setting
were tagged as device-intensive based on their APC assignment.
Codes in an APC where the device cost was 40% or greater of the over-
all cost in the HOPD were flagged as device-intensive. CMS is propos-
ing a change in this policy where procedures with a HCPCS code-level
device offset of greater than 40% of the APC costs when calculated
according to the standard OPPS APC rate-setting methodology would
be designated as ASC device-intensive. For new HCPCS codes describ-
ing procedures requiring the implantation of medical devices for which
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3
Coding & Billing
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