By Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H
Last week, AHRA’s Regulatory Affairs committee submitted comments on the 2017 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule (CMS-1656-P) and on the 2017 Medicare Physician Fee Schedule (MPFS) proposed rule (CMS-1654-P).
AHRA’s comments focused on clarification of the modifier requirement for reporting imaging services taken with film, implementation of the site neutral payment policy, and the proposed Ambulatory Payment Classification (APC) consolidation.
CMS has proposed that hospitals utilize an “XX” modifier to report imaging services taken using film versus digital (CR or DR) technology. AHRA has asked for clarification as to whether this modifier is truly “XX” or if this is placeholder for a future to-be-named modifier. Also, AHRA has asked for clarification as to whether or not this policy will apply to Critical Access Hospitals (CAHs).
The CMS “site neutral” policies that require that any new off campus (greater than 250 yards away) facilities and/or new clinical families introduced into existing facilities after November 5, 2015 be paid under the MPFS vs OPPS is unduly burdensome for imaging services. Imaging services have seen considerable declines in reimbursement under the MPFS since 2004, and it would be insufficient for a hospital/health system to cover the costs of these services. Limiting the ability of existing off-site facilities to move and/or to expand their imaging services without financial penalty will potentially create a hardship for the patients and increase the likelihood that the patient may not obtain the necessary service. AHRA recommends that CMS exclude imaging clinical families from the listing and allow facilities to expand these services with no financial penalty.
CMS has proposed to reduce the number of imaging APCs from 17 to 8. This reduction will result in significant payment reductions for the most commonly performed outpatient US and MRI services. AHRA does not support the APC consolidation and recommends that CMS not implement this proposal but rather continue to map the existing codes into their own clinical families until such time that CMS can articular a clear concept and criteria for an alternative approach for clinical similarity.
AHRA’s comments focused on clarification of the modifier requirement for reporting imaging services taken with film and Appropriate Use Criteria (AUC) implementation.
As with the OPPS Proposal Rule, CMS has proposed that hospitals utilize an “XX” modifier to report imaging services taken using film versus digital technology. AHRA has asked for clarification as to whether this modifier is truly “XX” or if this is placeholder for a future to-be-named modifier. Also, AHRA has asked for clarification as to whether or not this policy will apply to Critical Access Hospitals (CAHs).
The Proposed Rule contained language that CMS would implement the requirement to consult AUC no earlier than January 1, 2018. Additionally, there is verbiage that states that CMS will not finalize a list of clinical decision support mechanisms (CDSMs) until mid-2017, which would leave only 6 months for an organization to select, procure, install, and implement the chosen CDSM. AHRA believes that this is clearly not feasible. For this reason AHRA has expressed strong reservations about the currently proposed timeline for AUC implementation and requests that CMS review the operational challenges regarding AUC adoption. In our comment letter, AHRA provided information on several of the operational challenges and highlighted the lack of clarity on some of the key issues such as how the use of AUC would be reported at a patient level to CMS. AHRA suggests that CMS adopt an implementation date of January 1, 2019, giving organizations 18 months to prepare for this monumental change.
Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H is the president of Coding Strategies, Inc. She is also a member of the AHRA Regulatory Affairs Committee. She can be reached at Melody.firstname.lastname@example.org.