REGULATORY REVIEW
offset percentage from 50 to 40 per- cent, still based on the device cost as a percentage of the overall cost when the procedure is performed in the HOPD setting. CMS looked at the device costs for codes in all APCs, not only APCs formerly designated device- dependent, when determining device- intensive status. While ASCA supported CMS’ decision to lower the threshold, we recommended further adjustments to allow even more procedures to migrate to the lower-cost ASC setting and cited a recent policy change that impacted HOPDs but not ASCs to argue that the device offset should no longer be based on the standard OPPS rate-set- ting methodology.
CMS had recently implemented comprehensive APCs under the OPPS, but not the ASC payment system. Comprehensive APCs were designed to bundle more codes that were often
ASCA has been consistently imploring CMS to refrain from adjusting the device portion of the payment by the local wage index.”
—Kara Newbury, ASCA
done in conjunction with each other under one primary code. ASCA staff worried that the lack of alignment in those APCs deemed comprehensive in the HOPD setting but not in the ASC setting would throw off the device- intensive calculations. We recom- mended once again that CMS estab- lish the threshold at 50 percent of the “unadjusted” ASC payment rate (rela- tive weight * conversion factor). This threshold mirrors the current policy for establishing device-intensive ser-
3 FLUID MANAGEMENT PRODUCTS FOR SURGERY
#1
ENVIRON-MATE® SAVE
SPACE!
WALL MOUNTED DESIGN
DM6000-2A #2
FM99
FILTER/MANIFOLD PROVIDES 4 CONNECTIONS FOR SCOPE,
SHAVER AND FLUID COLLECTORS. 500CC CAPACITY!
UNLIMITED FLUID CAPACITY! PAYS FOR ITSELF IN ONE YEAR!
NO MORE CANISTERS! #3
PROMETHEAN ISLAND 4400 FLOOR MAT
CALL US BEFORE YOU BUILD OR REMODEL! 800-201-3060
34 ASC FOCUS OCTOBER 2020 |
ascfocus.org
vices and pass-through payments under the OPPS, and since ASCs are not included in the new compre- hensive APCs, this is the policy that should be referenced. Acknowledging that this argument had not been successful in the past, ASCA suggested that if CMS pre- ferred to continue to determine device- intensive status based on HOPD rates, lowering the proposed 40 percent threshold to 30 percent would come close to accomplishing the same goal, since the ASC conversion factor at the time was approximately 60 percent of the HOPD conversion factor (30/50 = 60 percent). CMS ignored our pro- posal at the time and finalized the 40 percent device offset. Still, the number of device-intensive codes increased from 75 in 2014 to 137 in 2015 under this policy change.
2019 Payment Rule ASCA continued to advocate for the 30 percent threshold, and in 2019, CMS obliged. ASCA commended CMS for making this change and pro- vided data from the 50 to 40 percent threshold change to indicate the type of impact CMS might see with this new policy. In the first year following the effective date of that policy (2015), there was a marked reduction in sur- gical services affected by the policy being performed in the HOPD and an increase in affected procedures being performed in the ASC setting, result- ing in a net savings when comparing the total combined ASC and HOPD dollars spent for the impacted codes. There was clear migration of services from the HOPD to the ASC among the procedures affected by the changed device-intensive threshold, so ASCA anticipates a further reduction in the device-intensive threshold will lead to a further migration of services from the HOPD to the ASC. While we do not have 2019 volume data yet, we anticipate that increasing the number
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52
