remote, or satellite locations of a hospital, and another
to identify outpatient services furnished in off-campus locations that are not remote or satellite locations
of a hospital or a hospital emergency department.
CMS states that it expects the two new POS codes to
be available after July 1, 2015, at which time physicians
will be required to record these POS codes, as appropriate, on their professional claim forms. There will
be no payment adjustments for services rendered in
the off-campus HOPD setting; this change is solely
for data collection purposes.
This change stems from CMS’ desire to better
understand the growing trend toward hospital acquisitions of physician offices and the treatment of these
offices as off-campus, provider-based HOPDs from a
payment perspective. Currently, Medicare pays a separate facility fee to account for a portion of PEs incurred
by the hospital, often resulting in inappropriate payments made to off-campus, provider-based HOPDs.
Valuing new, revised, and potentially misvalued Current Procedural Terminology (CPT) codes is a part of
maintaining the MPFS.† Under the current process,
CMS issues “interim final” values for most of these
codes in the MPFS final rule. These values are implemented for the following year but are subject to public
feedback before being finalized at the end of the year.
The MPFS final rule revised this process, and going
forward values will be part of the MPFS proposed rule,
affording stakeholders an opportunity to provide feedback on proposed values in advance of implementation. Final values will be incorporated into the annual
MPFS final rule a few months later. The transition to
this revised process is set to begin in CY 2016, with full
implementation taking place in CY 2017.
CMS proposed modifying this process to support
a growing public demand for increased transparency
and time to prepare for payment changes. The ACS
supported CMS’ proposal overall and specifically sup-
ported including values for new, revised, and poten-
tially misvalued CPT codes in the annual proposed
rule. CMS considered ACS’ comments and changed
its policies to follow this process, which eliminates the
need for most “interim final” values.
One of the most significant changes in the MPFS final
rule calls for transitioning all 10- and 90-day global
codes to 0-day global codes. The transition for 10-day
global codes will begin in CY 2017, and the transition
for 90-day global codes will begin in CY 2018. CMS has
yet to develop a methodology for making this transition. CMS set forth a number of reasons as to why the
agency believes this transition is necessary, including
the following: to increase the accuracy of MPFS payment by basing payment rates more closely on the typical resources used, to avoid duplicative payments when
a patient receives postoperative care from a different
provider, and to facilitate the availability of more accurate data for new payment models and quality research.
Prior to the release of the final rule, the ACS submitted detailed comments to CMS stressing that the
agency should refrain from moving forward with this
proposal until a comprehensive analysis was conducted
to determine its effects on the provision of surgical care.
Because this wide-ranging proposal will affect more
than one-third of all CP T codes, the ACS asserted that
CMS should delay its implementation until stakeholders have had sufficient time to understand the effects
and provide meaningful comments about this policy.
The ACS comment letter also offered recommendations on a number of issues that CMS must resolve
before moving forward with the proposed policy. The
letter addressed CMS’ concern that the number and
level of postoperative services included in the value of
10- and 90-day global services fall short of accurately
reflecting the postoperative services that surgeons actually provide. The ACS questioned whether this policy
would result in patients not seeking follow-up care if
they had to make a co-payment for each follow-up visit
†All specific references to CPT codes and descriptions are © 2014 American Medical Association. All rights reserved. CPT and CodeManager are
registered trademarks of the American Medical Association.