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of device-intensive codes from 154 in 2018 to 264 in 2019 resulted in another shift in volume from the higher-cost HOPD setting to the ASC setting.


 Wage Index Application for Device Intensive Codes


Although this has not gotten as much attention as the change in the thresh- old for the device offset, ASCA has been consistently imploring CMS to refrain from adjusting the device por- tion of the payment by the local wage index. This is consistent with the agen- cy’s policy for separately payable drugs and biologics, and it is proba- bly not the case that a facility in a rural community is getting a better deal on devices than other ASCs. One exam- ple of how much the wage index can impact device-intensive codes is for a knee reconstruction code, CPT code 27429. The national rate for 27429 is currently $10,113.69 and CMS esti-


mates the device costs at $8,866.89. In rural Tennessee, where the local wage index is currently 0.7076, the current reimbursement rate for 27429 is $8,635.07, which is less than the device costs. There are currently 27 device-intensive codes for which the device cost exceeds the total reim- bursement rate in rural Tennessee and this issue impacts all communities with a lower wage index.


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Co-Pay Cap As explained in the Advocacy Spotlight department on page 38, there is a co- pay cap for Medicare beneficiaries— currently $1,408—when a procedure is performed in a hospital as either an inpatient or outpatient procedure. What- ever the difference is between what the patient would usually pay (20 percent of the reimbursement rate) minus $1,408, the hospital is made whole by the Medi- care program. While this did not impact ASCs as much in the past, as ASCA promotes better reimbursement poli- cies for ASCs and increases the number of device-intensive codes, which often also have some of the higher reimburse- ment rates in the ASC payment system, this patient co-pay cap available only when these procedures are performed in hospitals becomes a larger issue. In 2020, Medicare beneficiaries would have to pay more out of pocket to have their procedure done in the ASC set- ting for 125 of the 296 device-intensive codes. ASCA is working hard to get this changed legislatively so Medicare and its beneficiaries are not disadvantaged by this oversight in payment policy.


  her at 


 REGULATORY AND LEGISLATIVE NEWS FOR ASCs


 to stay up to date on the latest        


 


36 ASC FOCUS OCTOBER 2020 | ascfocus.org


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