CMS released the 2022 Proposed OPPS rule yesterday.  

The 863 page Proposed Rule contains a number of notable items including:

• CMS is not eliminating the inpatient only rule.  In the 2021 final rule, the IPO list was being eliminated over a 3-year period
• Addition of the 298 services back to the IPO list that were removed last year
• Increase in hospital outpatient payment rates by 2.3% 
• Increase ASC payment rates by 2.3% for ASCs that meet quality reporting requirements
• 2% reduction in payments for hospitals that fail to meet reporting requirements
• Required hospital transparency policy changes including an increase in the amount of penalties for noncompliance
• No changes in OPPS payment policies for clinic, emergency department hospital outpatient visits and critical care services
• Change in APC assignment for certain procedure codes
• Proposed exemptions to the 2 times rule that include certain skin procedures, imaging, radiation therapy among others
• Changes to the list of ASC covered surgical procedures
• Continued 2-year exemption from certain medical review activities related to the 2-midnight rule for procedures eliminated from the IPO list in 2021
• CMS is seeking comment on COVID-19 flexibilities and whether certain policies should remain permanent
• No new APC conversions to C-APCs
• No changes to payment status indicators

We recommend you read the entire Proposed Rule in order to identify all of the changes applicable to your facility.  The HBE team is available to assist you with the implementation of these important changes as well as provide assistance in preparing your staff through education and training. 

The Proposed Rule is available here:  https://www.cms.gov/medicaremedicare-fee-service-paymentascpaymentasc-regulations-and-notices/cms-1753-p


HBE’s team of coding and compliance experts is available to assist you with external reviews of your documentation, coding and reimbursement as well as providing customized education and training for your staff. We are also available to provide assistance with conducting risk assessments, internal investigations and policy and procedure development.

DISCLAIMER:  This newsletter only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel.