News: Outpatient payment system final rule includes measures to watch

CMS made certain concessions from its proposed site-neutral payment policies required by Section 603 of the Bipartisan Budget Act, but it is still moving forward with implementation January 1, 2017, according to the 2017 OPPS final rule.

In the final rule, released November 1, CMS finalized its proposed policy to pay off-campus, provider-based hospital outpatient departments (PBD) at non-OPPS rates for all items and services provided in “a mixed bag of payment rates and payment policies,” according to Jugna Shah, MPH, president and founder of Nimitt Consulting, Inc., in a Briefings on APCs article.

Additionally, since implementing comprehensive ambulatory payment classifications (C-APC) in 2015, CMS continued to revise the policy and add procedures. With 37 C-APCs already created, the agency has finalized 25 new C-APCs for 2017.

“A whopping 1,877 CPT codes are grouped into these newly finalized C-APCs,” says Valerie Rinkle, MPA, lead regulatory specialist and instructor for HCPro, in Middleton, Massachusetts. “As a result of this increase, the number of code combinations that qualify for a C-APC complexity adjustment have significantly increased from 66 in 2016 to 312 in the 2017 final rule.”

The complexity adjustment is applied when a primary procedure assigned to a C-APC is reported with other specified procedures also assigned to C-APCs or with a specified packaged add-on code. When the facility reports one of these combinations, CMS will increase the payable APC to the next higher APC in the clinical group, similar to DRGs on the inpatient side.

CMS is issuing a 1.65% net increase in OPPS payments for 2017 over the current conversion factor, according to the Briefings on APCs article. This includes a market basket increase of 2.7%, with reductions of 0.3% and 0.75% due to multifactor productivity and provisions of the Affordable Care Act, respectively.

These numbers do not take into account the 2% reduction in payments for all Medicare fee-for-service claims as a result of sequestration, which has been in place since April 2013. The sequestration reduction will continue until Congress acts.