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Payment Matters
November 9, 2011
CMS's New Application of an Old Policy: The Three-Day Payment Window and Wholly Operated Physician Practices
By: Thomas W. Coons
There is a modicum of good news in the final CY 2012 Physician Fee Schedule (PFS). CMS has decided to delay until July 1, 2012, implementation of the expanded scope of the three-day payment window to non-provider-based physician practices and clinics. The rule also provides a billing code to identify those services, so that payments to these physicians may be appropriately identified and reduced. CMS’s discussion of these changes can be found here: http://www.ofr.gov/(X(1)S(scowdohnuodekhblmbrwklwa))/OFRUpload/OFRData/2011-28597_PI.pdf
Click to continue...CMS Provides Further Adjustments to Hospital Outpatient Supervision Rules
By: Thomas W. Coons
In its final Outpatient PPS update for fiscal year 2012, which CMS put on the web November 1, 2011, the agency updated its hospital outpatient supervision rules in two important respects. First, it established a process by which interested parties may seek to change the classification of certain services from requiring direct supervision to requiring either general or personal supervision. CMS also clarified that the supervision rules apply to therapeutic services that may fall within discrete benefit categories and that are not, under the Medicare Act, considered to be services furnished “incident to” a physician’s professional services. The CMS discussion on these changes can be found here: http://www.ofr.gov/(X(1)S(scowdohnuodekhblmbrwklwa))/OFRUpload/OFRData/2011-28612_PI.pdf
As to the first matter, CMS announced that it has established a technical review process under which CMS’s existing APC Panel will consider requests that CMS assign supervision levels other than direct supervision to specific hospital outpatient therapeutic services. CMS will expand the APC Panel, which currently has 15 members, to include two representatives from small rural PPS hospitals and another two from critical access hospitals (CAHs). In doing this, CMS will give specific representation to those hospitals that have been particularly vocal about their difficulties in complying with the direct supervision requirements. Further, recognizing the difficulties that CAHs and small rural hospitals have faced in complying with the current requirements, CMS stated that it will continue through calendar year 2012 its policy of not enforcing the supervision requirements for these hospitals.
Click to continue...CMS Releases Calendar Year 2012 Physician Fee Schedule Final Rule with Comment Period
By: Mark A. Stanley
CMS has released its Calendar Year (CY) 2012 Final Rule with Comment Period for practitioners who are paid under the Physician Fee Schedule (PFS). The final rule impacts a variety of methodologies used to calculate physician payment, including the adjustment for geographic differences in practice expenses and the payment rates for the professional component of multiple advanced diagnostic imaging procedures. The final rule may be viewed here [PDF].
CMS anticipates that, without changes to current law, the Sustainable Growth Rate (SGR) adjustment to physician reimbursement will result in a 27.4 percent cut in payment rates for 2012. This adjustment has historically been reversed through congressional intervention. However, in light of the ongoing impasse over budget cuts required by this summer’s debt ceiling debate, the possibility looms that no legislative fix will be forthcoming. As a result, there is a very real possibility that a substantial reduction in physician reimbursement will occur with the CY 2012 PFS.
Click to continue...Calendar Year 2012 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Final Rule Released by CMS
By: Aaron J. Rabinowitz (bar admission pending)
CMS has released its Calendar Year (CY) 2012 final rule with comment period for outpatient services furnished in hospitals and ASCs. In addition to establishing payment rates for CY 2012, the final rule also expands the measures to be reported under the Hospital Outpatient Quality Reporting Program, and modifies the Hospital Value-Based Purchasing program. The final rule also establishes an exception process for expansion of physician-owned hospitals, which is otherwise strictly limited by the Affordable Care Act (ACA). The final rule may be viewed here [PDF].
CMS anticipates that total payments under the OPPS for CY 2012 will be approximately $41.1 billion, and that payments to ASCs will be approximately $3.5 billion.
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