In the recently published proposed rule related to the CY 2018 Hospital Outpatient Prospective Payment System (OPPS), the Centers for Medicare & Medicaid Services (CMS) announced that it is considering changes to the regulation governing the date of service (DOS) for clinical laboratory and pathology specimens.  The DOS rules are important to laboratories and hospitals because they dictate which party must bill Medicare for certain laboratory testing performed on stored specimens collected during a hospital procedure but ordered after the patient has left the hospital.  If revisions are ultimately finalized, the proposal could have significant business implications for independent laboratories and hospitals.

Continue Reading CMS May Decide to Permit Labs to Bill for Certain Tests Provided to Outpatients

Last week, the Centers for Medicare and Medicaid Services (CMS) released its proposed rule for the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC) Payment System for 2017. CMS proposed several new policies in the rule, including the implementation of Section 603 of the Bipartisan Budget Act of 2015 (BBA). Section 603 requires certain items or services provided by off-campus outpatient departments or “provider-based departments” (PBDs) to no longer be paid under OPPS but rather under the “applicable payment system.” The proposed rule provides only limited exceptions to this requirement, much to hospitals’ dismay.

Continue Reading CMS Releases Proposed Outpatient Payment System Rule for 2017, Leaving Hospitals Unhappy

Written by: Karen Lovitch and Lauren Moldawer*

As part of the Outpatient Prospective Payment System (OPPS) Rule issued last week, the Centers for Medicare & Medicaid Services (CMS) finalized its proposal to conditionally package certain ancillary services assigned to APCs with a “geographic mean cost” of $100 or less.  This change, which will take effect on January 1, 2015, will apply to the technical component of most anatomic pathology services.  Because the hospital’s payment for the primary procedure will cover these services, the hospital may no longer bill for them separately.  But physicians can continue to seek reimbursement under the Medicare Physician Fee Schedule for the professional component of the service. Continue Reading CMS Finalizes OPPS Rule Packaging Pathology Services Ordered for Hospital Outpatients