Summary of CY14 Hospital Outpatient Prospective Payment System (HOPPS) PROPOSED rule

The purpose of this post is to highlight issues raised in Medicare’s CY2014 HOPPS proposed rule:

  • It was released on www.cms.gov on Friday, July 8, 2013
  • Published in the Federal Register on July 19, 2013
  • CMS will accept comments until 5pm (EST), Friday, September 6, 2013
  • CMS provides a very nice summary press release that should be reviewed
  • If an issue interests you, please submit a comment by September 6, 2013
  • It is VERY easy to submit an electronic comment @ www.regulations.gov
  • For additional information and/or personal discussion, please call me at 203-271-3366

Here are the issues that interest me as they relate to medical devices….

  • Total CY14 OPPS payments are projected to increase by $4.37 billion (9.5%).
  • Total CY14 ASC payments are projected to increase by $133 million (3.51%).
  • CMS proposed CY14 HOPPS conversion factor = $72.728.
  • CMS proposed CY14 ASC conversion factor = $42.462
  • CMS did not identify any procedures that potentially could be removed from the “inpatient list”
  • CMS did not identify any procedures that could be added to the ASC covered list.
  • CMS proposes to add seven (7) additional categories of support services related to items & services packaged into a single payment for the primary service:
  1. Drugs, biological & radiopharmaceuticals that function as supplies when used in a diagnostic test or procedure.
  2. Drugs & biological that function as supplies or devices when used in a surgical procedure. (Heads-up to all wound care companies. See comment below*).
  3. Certain clinical diagnostic laboratory tests.
  4. Procedures described by add-on codes.
  5. Ancillary services, such as chest-xrays, that are assigned status indicator “X”.
  6. Diagnostic tests on the bypass list.
  7. Device removal procedures.

* Any wound care company MUST read the “skin substitutes” preamble (page 168 @ www.cms.gov). Please see the attached list of skin substitute products that would be unconditionally packaged under this proposal and assigned to status indicator “N” for CY14. Proposed APCs to which skin substitute procedures would be assigned for CY14 are:

  • APC 135: Level III Skin Repair, National Average proposed payment = $874.71
  • APC 136: Level IV Skin Repair, National Average proposed payment = $1,377.25

This is the most controversial proposal in Medicare’s CY14 HOPPS proposed rule. It warrants comments from healthcare providers, patients and manufacturers. For personal discussion, please do not hesitate to call me @ 203-271-3366.

  • CMS proposes to create 29 comprehensive APCs to replace 29 existing device-dependent APCs.
  • Low dose rate (LDR) Prostate Brachytherapy Composite APC 8001 (page 138 @ www.cms.gov).
  • Cardiac EP Evaluation & Ablation Composite 8000 (page 140 @ www.cms.gov).

For more information and/or personal discussion, please call me @ 203-271-3366 or kathryn.barry@kbreimbursement.com