All Entries Tagged With: "Brachytherapy"
More on the OPPS proposed rule
Earlier this week, I discussed the physician supervision provisions of the CY2010 OPPS proposed rule.
Another section of interest to many providers will be the sections on the new cardiac rehab, intensive cardiac rehab and pulmonary rehab benefits. CMS discusses their implementation of these new benefits added to the Social Security Act by the MIPPA, effective January 1, 2010. Of particular interest is CMS implementation of the MIPPA provision that states that physician supervision for these programs is assumed when provided in a hospital.
Other significant proposals in the rule include a large proposed increase in the OPPS outlier threshold from $1800 to $2,225, the highest the fixed dollar threshold has been since its introduction.
Additionally, a significant portion of the rule was also devoted to payment methodologies for drugs, however, the end resultant proposal for most drugs remains at ASP + 4%. This includes ASP based payment for therapeutic radiopharmaceutical when the statutory cost based payment methodology expires in 2009. CMS did make the submission of ASP data for therapeutic radiopharmaceutical voluntary, and will base rates on CY2008 hospital mean cost data if ASP is not available.
Similarly, brachytherapy sources, which also were under a statutory cost based payment methodology for 2009, will be transitioned to CY2008 hospital mean cost data (the usual method for setting APC rates for other services). CMS is soliciting comments on several of their proposals and I would encourage pharmacy, radiology and chargemaster coordinators to review these proposals carefully and submit comments if they disagree with any of the proposals.
Important CY 2009 OPPS status indicator changes
SIs “N,” “Q1,” Q2,” and “Q3”
In CY 2008, CMS greatly expanded the number of packaged items and services payable under the Outpatient Prospective Payment System (OPPS). More than 300 items and services that had formerly been separately payable became packaged, at least in certain circumstances. CMS is continuing this trend in CY 2009. Presently, there are four status indicators (SI) that identify packaged items and services: “N,” “Q1,” “Q2,” and “Q3.” Addendum D1 to the CY 2009 OPPS final rule defines SI “N” as identifying items and services that are paid under the OPPS; however, there is no separate payment for them. Instead, payment is included in the payment for other items and services. Think of those services as “never” being separately payable.
There are a number of other items and services that are “sometimes packaged” and “sometimes separately payable.” In 2008, all of the “sometimes packaged” items and services were identified with the “Q” SI. These “Q” SI codes were then further divided into three subcategories, which established the criteria for determining whether they would be packaged or separately payable in particular circumstances. Those three subcategories were as follows: [more]
