The ACC has submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) regarding proposed updates to the 2019 Hospital Outpatient Prospective Payment System (OPPS).

The ACC's comments focus on several elements of the proposed rule, including support for updates to the ambulatory payment classifications (APCs) for imaging and endovascular procedures, with recommendations, and discussion of cost-allocation methodologies for reporting data used to calculate annual cost-to-charge ratios and APC relative weights. In addition, the letter addresses concerns regarding proposals that would limit the scope of off-campus provider-based departments (PBDs), including one in which reimbursement for clinic visits provided under the OPPS in exempted off-campus PBDs would be equal to the Physician Fee Schedule rate for office visits.

The comments also express support for the addition of 12 diagnostic cardiac catheterization services to the list of procedures that would be covered at ambulatory surgery centers, while also tackling critical issues CMS must evaluate as it considers expanding the secretary's authority to further limit unnecessary increases in outpatient department utilization. "Patient safety and outcomes must be a priority over the cost of care. Shifting services to a lower cost setting should only be done when supported by clinical guidelines and when CMS can ensure that such a shift will not harm the quality of care received by a patient," the letter states.

Other topics addressed by the comment letter include the Hospital Outpatient Quality Reporting Program; price transparency; and promotion of interoperability and electronic health care information exchange through possible revisions to the CMS Patient Health and Safety Requirements for Hospitals and Other Medicare- and Medicaid-Participating Providers and Suppliers. In terms of price transparency, the College urges that quality metrics and policies "be in place to recognize clinicians and providers for engaging in shared decision-making discussions involving the cost of care" should CMS "eventually require clinicians and health care providers to inform patients on their out-of-pocket costs."

The final rule is expected this fall.

Clinical Topics: Cardiovascular Care Team

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Outpatients, Medicare, Fee Schedules, Medicaid, Cardiac Catheterization

< Back to Listings