REGULATORY REVIEW ■■
Most outpatient departments are equipped to provide the services to the Medicare population.
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The simplest procedure described by the code may be performed in most outpatient departments.
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The procedure is related to codes that [CMS has] already removed from the IPO list.
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A determination is made that the pro- cedure is being performed in numer- ous hospitals on an outpatient basis.
A determination is made that the procedure can be appropriately and safely performed in an ASC, and is on the list of approved ASC pro- cedures or has been proposed by [CMS] for addition to the ASC list. In addition to removing TKA from the IPO list, CMS also is requesting comments on whether PHA, CPT code 27125, and THA, CPT code 27130, should be removed from the IPO list.
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Of utmost interest to ASCA and our members, the agency is seeking feed- back on the potential for adding all three codes to the ASC-payable list in the future. CMS is specifically seeking public comments on the following questions: ■■
Are most outpatient departments equipped to provide PHA and/or THA to some Medicare beneficiaries?
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Can the simplest procedures de - scribed by CPT codes 27125 and 27130 be performed in most outpa- tient departments?
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Are the procedures described by CPT codes 27125 and 27130 suf- ficiently related or similar to other procedures CMS has already removed from the IPO list?
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How often are the procedures described by CPT codes 27125 and 27130 being performed on an out-
patient basis (either in an HOPD or ASC) on non-Medicare patients?
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Would it be clinically appropri- ate for some Medicare beneficia- ries, in consultation with their sur- geons and other members of the medical team, to have the option of either a PHA or THA procedure as a hospital outpatient, which may or may not include a 24-hour period of recovery in the hospital after the operation?
CMS also is seeking feedback
regarding whether these codes meet any of the exclusionary criteria that would keep them off the ASC-payable list.
Exclusionary Criteria The ASC list of covered procedures is an “exclusionary list,” meaning ASCs are allowed to perform any surgical procedure that is not designated as an “inpatient only procedure” unless
ASC FOCUS OCTOBER 2017 |
www.ascfocus.org
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