![博客Cms最终裁决全尺寸](/Areas/CMS/assets/img/blank.gif)
Nearly a year to the day that the Bipartisan Budget Act of 2015 (BBA) promised to dramatically change how hospitals are reimbursed for outpatient procedures, 上周,CMS发布了最终规定, which offer guidance on interpreting the legislation.
Section 603 of the BBA requires that hospitals bill under the lower-reimbursing Medicare physician fee schedule (MPFS) in place of the outpatient prospective payment system (OPPS) for any off-campus location not providing services as of November 2, 2015. The shift will have a significant financial impact for hospitals, particularly those that are actively planning for an off-campus department.
In a follow-up to 心电图’s previous blog posts covering the 历史,关键的变化,和 预期的影响 这条法律, this post describes the final rulings on the most significant changes, and discusses the questions and next steps hospitals should be considering.
什么是清晰的?
The original legislation was unclear about several key changes to billing under OPPS (otherwise known as provider-based billing):
- “校园”的定义
- Ability of an organization to relocate an off-campus department
- Future of potential expansions to off-campus departments
- 独立急诊科的状况
- 指定远程设施
最终规定将于11月1日公布, 2016, 为医院提供了更清晰的信息, which should enable them to move forward with stalled or uncertain future plans. Key issues and concerns addressed in the final rules can be found below.
问题 | 关注 | 决议 |
在校园 | “On campus” was specified as being within 250 yards of the main campus. The primary concern was how to measure 250 yards:
| The 250 yards measurement is from any point of the main facility to the on-campus facility, and the entire facility need not be within 250 yards. |
搬迁 | Changing the address of a current OPPS-eligible facility would cause a loss of OPPS grandfathered status. | CMS indicated it would provide additional guidance in the future specifying the potential reasons for a relocation, but noted that temporary or permanent relocations would be allowed for circumstances beyond the provider’s control, 比如自然灾害. |
扩张 | Expanding service offerings of a current OPPS facility by adding new or complementary services would cause the loss of OPPS grandfathered status. | While CMS did not provide additional clarity on the status of expanding clinic offerings, it did recognize the potential concerns raised by provider organizations. 在做最后的建议之前, CMS plans to monitor service expansions and changes in current facilities in order to better understand the scope and impact of expansions. |
应急部门 | 云顶集团 in a dedicated emergency room should be exempt from this ruling. | CMS同意, and finalized rules to exempt emergency departments from the restrictions imposed by the BBA. |
远程设备 | Off-campus departments should qualify for OPPS status if they lie within 250 yards of existing remote locations of the main hospital (such as a rehabilitation facility). | While CMS did not directly address this concern, the language indicates that remote locations of a main hospital may be used to define outpatient departments if the outpatient facilities are within 250 yards of the remote locations. |
未来会怎样?
While Section 603 of the BBA was an unwelcome surprise for many hospitals and health systems that rely on the higher reimbursements provided by OPPS billing to subsidize other areas of hospital operations, it is likely a sign that more changes are on the way. The Medicare Payment Advisory Commission (MEDPAC) has been vocal about the need to site-neutralize reimbursement, and this legislation demonstrates CMS’s first major step toward heeding that recommendation.
在过去, MEDPAC has made additional recommendations about reducing the use of evaluation and management (E&M) codes within hospitals and terminating any “grandfather” clauses that allow organizations to obtain higher reimbursements through a historical ruling. It is likely that MEDPAC’s recommendations to CMS will continue to support reductions in reimbursement variation across sites, 的情况下, 和云顶集团. Organizations will need to be cognizant of their past reliance on provider-based billing and recognize deficiencies that it may be concealing. Key questions hospital administrators should be asking themselves include:
- 我的组织在哪里使用OPPS计费, and what would be the impact on the hospital’s bottom line of converting to the MPFS?
- What are the threats to my organization if OPPS billing goes away entirely?
- How can I better assess deficiencies that provider-based billing has been masking, potentially by evaluating my current compensation plans, 病人的访问, 支付合同, and costs to operate more efficiently in a new reality?
Regardless of how the final ruling affects your organizational plans today, Section 603 of the BBA should be seen as a clear indicator of what is likely to come.
出版于2016年11月10日