Centers for Medicare and Medicaid Services (CMS) released proposed regulations earlier this week for the hospital outpatient departments (HOPDs) and ambulatory surgical centers (ASCs) for. Additionally CMS released annual proposed changes to the Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP). Both proposed rules are for calendar year (CY) 2020. Comments are due no later than 5 p.m. EST on September 27, 2019.
Initial review of the HOPD and ASC proposed regulation include:
- Disclose insurer-negotiated prices and enforcement plan.
- CMS would require hospital websites to display payer-specific negotiated charges for at least 300 “shoppable services” which is defined as a service that can be scheduled by a health care consumer in advance. CMS would designate 70 of the service charges that must be included in the list, and the hospital would have to choose the remaining 230.
- Hospitals that did not comply with the regulations could face a monetary penalty of up to $300 per day until they are in compliance or provide a corrective action plan.
- Changes to Inpatient and Ambulatory Surgical Center Covered Procedure List
- Proposed this year include remove total hip arthroplasty (THA) from the inpatient only list while total knee arthroplasty (TKA) would be added to the ambulatory surgical center services eligible
- Phase-in site neutral payments
- CMS is proposing moving forward with an additional 30% cut. This will bring the national average payment rate will go down from $116 per visit to just $46.
Initial review of the MPFS and QPP proposed regulation include:
- For the second year, implement pricing updates based on market specific supply and equipment prices, malpractice expenses, and geographic-based practice costs.
- CY 2020 PFS conversion factor would be $36.09, a slight increase above the CY 2019 PFS conversion factor of $36.04.
- Moving back to an evaluation and management (E/M) five-tier visit code system for patients and suggested moving to a four-tier coding system for new patients.
- Suggested adapting the revised E/M code definitions developed by the American Medical Association (AMA).
- Adopting the AMAs RUC-recommended payment rates in which CMS would make payments based on each level of service versus single blended rate for codes level 2-4
- Consolidating add-on code for “extended visit” to primary care management that requires comprehensive care as well as for non procedural specialty care that is part of treating complex chronic conditions.
- Requesting comments on changes to global surgery coding
- Increasing Medicare transitional care management payments for clinicians when a patient leaves the hospital
- Changes under QPP’s Merit-based Incentive Payment System (MIPS) in the cost and quality performance category
- Expand Medicare coverage for opioid use disorder treatment services
