HOPPS rule proposes outpatient bundles for endovascular repairs

Just in time for your summer reading pleasure, the ACR has posted detailed summaries of the proposed rules for the 2015 Medicare Physician Fee Schedule and the 2015 Hospital Outpatient Prospective Payment System.

For the first time, CMS introduces bundling in the hospital-based outpatient setting, naming them comprehensive ambulatory payment classifications or C-APCs. The proposed rule includes 28 device-dependent C-APCs, two of which are raising concerns at the ACR.

Pamela Kassing, senior economic advisor for ACR, told Modern Healthcare that two of the three C-APCs involving endovascular revascularization—C-APC 0083 (Level I Endovascular Procedures); C-APC 0229 (Level II Endovascular Procedures); and C-APC 0319 (Level IV Endovascular Procedures)—represent 85% of all imaging services that would be packaged under the new codes.

“There is a lot of imaging involved in those APCs,” she told the magazine, saying that ACR would meet with CMS this fall to represent radiologist interests.

Medicare also announces in the proposed rule that it intends to look into whether the trend in physician practice acquisition has resulted in higher cost to Medicare. MedPAC suggested equalizing payment between physician office and hospital-based outpatient reimbursement, because many physician offices are able to bill under HOPPS rather than the lower-paying MPFS after being acquired by a hospital.

To investigate whether this trend is raising Medicare costs, CMS proposes the use of a HCPCS modifier be used with every code for physician services and outpatient hospital services provided in an off-campus provider-based department of a hospital, according to the ACR detailed summary of the proposed HOPPS rule.

As previously reported, the proposed MPFS rule includes changes to practice expense (PE) relative value units (RVUs) for x-ray, driving a 2% reduction in overall reimbursement for radiology. Interventional radiology will experience a 1% overall reduction—due partly to the proposal to prohibit the billing of image guidance codes with four epidural injection codes— and radiation oncology will experience a 4% reduction, with the greatest pain reserved for radiation therapy centers: an overall 8% reduction in reimbursement.

Based on the RUC recommendation that all imaging codes, including mammography, be valued using digital rather than film inputs, CMS has proposed that all digital mammography codes be reviewed by RUC as potentially misvalued, according to ACR’s detailed summary of the proposed rule.