ASCs Can Look Forward to Reporting Integral Services

Also, Stark law will relax to allow more self-referrals
The 2008 Final Rule for ASCs will allow your POS 24 facility to receive separate reimbursement for ancillary services, including radiology services, that until now you have not been able to report. To gain that payment, however, the ancillary service must meet certain standards.

Evidence of Necessity Is a Must

Changes under the "Revised Payment System Policies for Services Furnished in Ambulatory Surgical Centers (ASCs) Beginning in CY 2008" (ASC 2008 Final Rule) will allow you to gain separate payment from Medicare, in an ASC setting, for a number of previously-excluded items, including:
• radiology services
• drugs and biologicals (for instance, certain Level II Q and J codes) that are separately payable under the outpatient prospective payment system (OPPS)
• devices that are eligible for pass-through payments under the OPPS (Level II C codes). Pass-through payments allow facilities to gain reimbursement for newer drugs and biological products that CMS had not yet packaged into ambulatory payment classification (APC) groups (which will govern ASC reimbursements starting Jan. 1). Products remain on the pass-through list for at least two but not more than three years and are then bundled into an APC group for their associated medical procedure or assigned a separate APC code.
• brachytherapy sources, and
• corneal tissue acquisition.

All told, the final rule lists 22 pages of codes (more than 1,000) describing ancillary services now eligible for separate payment in an ASC. The changes create a high level of consistency between ASC and OPPS guidelines, comments Joyce L. Jones, CPC, CPC-H, CCS-P, CNT, director of business operations at AMSURG in Nashville, Tenn.
Crucial: As a requirement of separate reporting, you should be able to substantiate that the ancillary service is "integral to a covered procedure" and provided "immediately before, during or immediately after" that procedure, according to the final rule.
In other words: If an ancillary service isn’t immediately necessary to perform a covered, primary service, you can’t report the ancillary service. For instance, you couldn’t code for a "diagnostic" radiology service for a patient not scheduled for a related primary procedure, Jones notes.

Adjust Your Payment Expectations

In most cases, you can expect that payments for ancillary items will just cover the costs of providing the item. CMS will reimburse for separately-payable drugs and biologicals, as well as brachytherapy sources, at a rate identical to that provided to hospital outpatient facilities, without adjustments for geographic wage differences. For devices that have pass-through status under the OPPS, payments are pegged to contractor-priced rates. [...]

- Published on 2007-11-27