AACU Minute: AACU comments on proposed 2017 outpatient facility and ASC payment rates
The AACU submitted comments September 1, 2016, on a proposed rule regulating hospital-based outpatient and ambulatory surgical center (ASC) Medicare payment rates for calendar year 2017.
Overall, the Centers for Medicare and Medicaid Services (CMS) proposal would increase hospital-based rates by 1.55% and ASC rates by 1.2%. The positive 'update' is notable in contrast to last year's adjustment, which cut payment rates for the first time in several years.
For the past several years, policymakers have discussed site-neutral payments as a mechanism for savings in the outpatient space. A 'site-neutral' payment policy would eliminate the difference between hospital-based and non-hospital based outpatient facility payment rates, thus reducing rates for some hospital-based services to non-hospital based rates and ultimately decreasing Medicare's outpatient costs.
Many stakeholders were disappointed by exceptions CMS proposes in the site-neutral payment changes, including:
- All items and services furnished in a dedicated emergency department
- Items and services furnished and billed by an off-campus, provider-based department before November 2, 2015
- Items and services furnished in a hospital department within 250 yards of a remote location of the hospital
The AACU's comments on the proposed rule touched on the following points:
- We support the proposed change from APC 1565 to APC 5376 (Level 6 Urology and Related Services).
- We agree with the proposed move from a Status Indicator (SI) T to J1, Comprehensive APC status.
- We agree with the proposed shift from status indicator (SI) G2 (non office-based surgical procedure) to J8 (device intensive procedure). This change is essential to allow for appropriate ASC payment and will allow more Medicare patients access to this treatment option.
- We support the proposal to revise the device-intensive calculation methodology and calculate at the HCPCS code level rather than at the APC level to ensure that device-intensive status is properly assigned to all device-intensive procedures. This change will result in ASC payments that have less fluctuation, thereby allowing more Medicare procedures in this efficient site of service.
- AACU comment letter (Sept. 1, 2016)
- Proposed Rule (CMS-2016-0115)
- CMS releases OPPS proposed rule for 2017: 12 things to know (Becker's Hospital CFO, July 07, 2016)
- CMS proposes 1.2% ASC payment increase in 2017: 9 key points (Becker's ASC Review, July 07, 2016)