The 2023 OPPS and ASC Proposed Rule was released on Friday.  The 886 page document contains a number of important proposals including:

• Increase in hospital outpatient and ASC payment rates by 2.7%
• 2% reduction in payments for hospitals and ASCs that fail to meet quality reporting requirements
• New payment methodology for certain procedure combinations performed in an ASC.  The new model would be comparable to that of the complexity adjustment/comprehensive APC model in a hospital outpatient setting.
• New payment methodology and enrollment instructions for rural emergency hospitals (REH)
• Payment for 340B is proposed at the current rate rate of average sales price (ASP) minus 22%.  However, CMS has indicated they anticipate the final rule will reflect a rate of ASP plus 6%.  Additional changes are anticipated.
• Reimbursing clinic visits rendered in an excepted provider based clinic of a sole community hospital at the full OPPS rate rather than the decreased physician fee schedule equivalent rate 
• Removal of 10 services from the inpatient only list (IPO) which are primarily maxillofacial procedures
• Addition of 8 services for newly created CPT codes to the IPO list which are primarily hernia repairs
• Addition of 1 service to the ASC Covered Procedures List (CPT 38531 – inguinofemoral lymph node biopsy or excision)
• Coverage of mental health services furnished remotely by hospital staff to beneficiaries in their home with the creation of OPPS-specific coding

We recommend you read the entire Proposed Rule in order to identify all of the changes applicable to your facility.   

The Proposed Rule is available here:  https://public-inspection.federalregister.gov/2022-15372.pdf

The CMS Fact sheet is here:  https://www.cms.gov/newsroom/fact-sheets/cy-2023-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center

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 contains 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.