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CMS Advisors Recommend Hospital Payment for Advance Care Planning

Panel critiques current OPPS regulations

Health care industry stakeholders, including providers, technology vendors, and payers, are working overtime to ensure that their systems are ready for the imminent ICD-10 implementation. But the rest of the Centers for Medicare & Medicaid Services’ (CMS) regulatory slate, such as the annual update to the outpatient prospective payment system (OPPS), continues, according to an article posted on the Health Information Management website.

The Advisory Panel on Hospital Outpatient Payment (HOP), which consists of full-time employees of hospitals, hospital systems, and other Medicare providers as well as stakeholders, met recently at CMS headquarters in Baltimore, Maryland, to provide feedback to the agency. The HOP meets at least twice a year and invites stakeholders to publicly submit comments regarding OPPS regulations. The panel can subsequently vote on whether to make recommendations to CMS based on those comments.

A HOP meeting held last summer resulted in very little action, with only one vote that ended in a tie, Health Information Management columnist Steven Andrews reports. But the recent meeting included more interaction between commenters and the panel, with several recommendations that could affect future policy sent to the CMS.

One topic that received a lot of attention, Andrews says, was hospital payment for advance care planning. In the 2016 Medicare Physician Fee Schedule proposed rule, the CMS offered payment for two advance care-planning current procedural terminology (CPT) codes. One is an initial code for 30 minutes of discussion on advance care planning, and the second is an add-on code for each additional 30 minutes. For outpatient hospitals, however, the codes have been assigned status indicator N (no additional payment; payment included in line items with ambulatory payment classifications [APCs] for incidental service).

Providers at the HOP meeting questioned whether this was simply an oversight on the part of the CMS. However, John McInnes, MD, JD, director of the Division of Outpatient Care at the CMS, specified that it was intentional on the agency’s part.

These services are provided by licensed and credentialed hospital staff, in conjunction with physicians and other midlevel practitioners, and hospitals should be compensated separately under the OPPS, said Jugna Shah, MPH, president and founder of Nimitt Consulting, based in Washington, D.C.

In addition to compensating hospitals for providing these services, CMS would be able to collect detailed data on the effect of advance care planning on patient satisfaction and outcomes, Shah said.

Shah asked the panel to recommend to the CMS that the initial CPT code be assigned to APC 5012 (level 2 examinations and related services) and that the add-on code be assigned to APC 5011 (level 1 examinations and related services).

After some debate, the panel voted 8-to-5 to recommend those changes to the CMS.

The October issue of Briefings on APCs will feature additional coverage of the HOP meeting and of the recommendations made to the CMS.

Source: Health Information Management; August 28, 2015.


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