that could benefit a certain code, but often it results in a drop in pay-
ment if CMS feels the code is more clinically similar to codes in a
lower-paid APC group.
Why won't CMS reimburse ASCs for devices?
Unless the device accounts for at least 40% of the total payment
when performed in the HOPD setting, CMS views the device as a part
of the facility fee payment. While the device portion of the reimburse-
ment rate is the same regardless of surgical setting, CMS pays ASCs
the lower amount for the non-device portion of the service, which will
be about 50% of the HOPD rate for 2017. Even though CMS divides
the payment into a device portion and a non-device portion, there is
no separate payment.
Let's say the device accounts for $399 of a $1,000 case in an HOPD.
Since it's under the 40% threshold, the device is not incorporated into
the rate. For the same case, an ASC would receive about $500 (50% of
the HOPD rate), $399 of which the device eats up, leaving $101 for
payment for the case. Highly unlikely the ASC would perform this
procedure.
CMS dropped the device threshold in the 2015 final payment rule
from 50% to 40%. But due to the large disparity in the non-device por-
tion of the reimbursement rate, many in the ASC community feel a
threshold of 30% would be more appropriate. CMS clearly doesn't want
to incentivize ASCs to perform device-intensive procedures. In the
2017 final rule, CMS states that "a lower device offset percentage in the
ASC setting would result in more device-intensive procedures, when
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D E C E M B E R 2 0 1 6 • O U T PA T I E N TS U R G E R Y. N E T • 2 5
In 2017, ASCs will be reimbursed about 50% of what
HOPDs receive for the same surgical services.
