CMS Delivers an Unwelcome ‘Package’ -- What You Should Know to Protect the Bottom Line

Also, expect more ‘composite’ APCs in the future
CMS’ Final Rule for 2008, covering changes to the hospital outpatient prospective payment system and ambulatory surgical center payment system, brings bad news for all providers dependent on APC payments. By "packaging" more supplies and services into APCs, CMS seeks to control costs by putting the squeeze on facilities.

Increase Your Efficiency, or Pay the Price

Beginning Jan. 1, you will no longer receive separate reimbursement for many ancillary services for which, until now, you could receive payment. Citing a desire to "create incentives for hospitals to seek ways to provide services more efficiently than exist under the current OPPS structure and allow hospitals maximum flexibility to manage their resources," CMS will now "package" several hundred services or supplies in six categories:
• Guidance services
• Image processing services
• Intraoperative services
• Imaging supervision and interpretation services
• Diagnostic radiopharmaceuticals
• Contrast media.

For instance, the Final Rule explains, "[CMS] proposed to change the status indicator for 33 imaging supervision and interpretation services from separately paid to unconditionally packaged for the CY 2008 OPPS." The agency defends the packaging strategy by stating, "We believed that these services are always integral to and dependent upon the independent services that they support and, therefore, their payment would be appropriately packaged because they would generally be performed on the same date and in the same hospital as the independent services."
The agency made similar comments regarding the other newly packaged services, such as this statement on radiopharmaceuticals: "We believe that it is most appropriate to package payment for some radiopharmaceuticals, specifically diagnostic radio-pharmaceuticals, into the payment for diagnostic nuclear medicine procedures for CY 2008. We expect that packaging would encourage hospitals to use the most cost- efficient diagnostic radiopharmaceutical products that are clinically appropriate."
"The impact of these changes on reimbursement will be significant in some circumstances," says Sarah L. Goodman, MBA, CPC-H, CCP, president of SLG Inc. in Raleigh, N.C. As just one example, Goodman cites a case in which a physician examines a patient and orders a same-day venography.
In 2007, you could have received reimbursement for both the visit (CPT 99213, APC 0605) and the vein x-ray (CPT 75820, APC 0668), for a total of more than $440. The new Final Rule, however, includes the x-ray in the E/M, dropping your payment to about $65.
Resource: CMS provides a complete list of "packaged" codes (CPT/HCPCS) in Table 10, beginning on page 313 of the Final Rule, available for download in PDF format at www.cms.hhs.gov/HospitalOutpatientPPS/Downloads/cms1392fc.pdf.
All codes in [...]

- Published on 2007-01-20