Overview of CV-Related Provisions From the 2024 OPPS Final Rule

The Centers for Medicare and Medicaid Services (CMS) released the CY 2024 Hospital Outpatient Prospective Payment System (OPPS) final rule on Nov. 2. The rule will implement a 3.1% increase to OPPS payment rates that reflects a market basket update of 3.3% reduced by a productivity adjustment of 0.2%.

Additional highlights relevant to cardiovascular clinicians include:

  • Cardiac Positron Emission Tomography (PET)/Computed Tomography (CT) Studies: CMS finalized the proposed ambulatory payment classifications (APC) for codes 78431 and 78433, which will result in a reduction in reimbursement for 78431 back to the 2022 rate and no change to 78433. In response to comments from the ACC, American Society of Nuclear Cardiology and others, CMS amended its proposal for 78432, leaving the code in its current APC instead of moving it to an APC that would have reduced its reimbursement. CMS recognized the College’s request for more narrow pay bands among APCs to avoid significant swings in reimbursement year to year depending on variable claim data and will consider the suggestion for future rulemaking. 
  • APC Complexity Adjustments: The ACC argued for complexity adjustment system reform so that important ancillary services such as Fractional Flow Reserve, Intravascular Ultrasound and others would be more accessible to patients without a financial disincentive to the facilities performing the services. CMS finalized APC Complexity adjustment policy for 2024 as proposed, but noted suggested changes and will consider for future rulemaking.
  • Supervision by NPs, PAs, and CNSs of Cardiac Rehabilitation (CR), Intensive Cardiac Rehabilitation (ICR) and Pulmonary Rehabilitation (PR) Services Furnished to Outpatients: CMS finalized proposed regulatory changes to conform with the ACC-championed Improving Access to Cardiac and Pulmonary Rehabilitation Act, which passed as part of the Bipartisan Budget Act of 2018. In response to comments suggesting that virtual direct supervision of CR, ICR and PR be permanent, CMS noted that the flexibilities were extended for a year to continue gathering data on safety, quality of care and other considerations that can be applied to the suggestion in future rulemaking.
  • Expiration of Transitional Pass-Through Payment for Coronary Intravascular Lithotripsy: CMS did not extend the transitional pass-through payment or assign the procedures most often performed with IVL to an APC with higher reimbursement. As a result, payment for IVL in the outpatient setting from July 1, 2024, through Dec. 31, 2024, will be bundled as part of the underlying PCI service.   
  • Cardiac Ablation Services Not Added to Ambulatory Surgical Center (ASC) Covered Procedures List (CPL): In response to comments emphasizing the ambiguity and lack of transparency in the process to request codes be added to the ASC CPL, CMS has developed a webinar on the process that is anticipated to be publicly available by Jan. 1, 2024. For reference, only 11 of 235 procedures submitted for the ASC CPL were accepted in this rule.
  • Inpatient-Only List (IPO): No cardiovascular changes were made to the IPO.
  • ASC CPL: No cardiovascular changes were made to the ASC CPL.
  • Excessive Radiation Electronic Clinical Quality Measure (eCQM): CMS finalized the addition of this measure, previously referred to as Excessive Radiation Dose or Inadequate Image Quality for Diagnostic CT in Adults eCQM, to the Hospital Outpatient Quality Reporting Program Measure-Set, with mandatory reporting beginning in 2027.
  • Hospital Outpatient/ASC Facility Volume Data on Selected Outpatient Surgical Procedures: After consideration of feedback, the proposal to readopt the measure will not be implemented.
  • Hospital Price Transparency: CMS finalized changes aimed at increasing price transparency through standardization of machine-readable files that can be used to create patient-friendly displays.

Access the full OPPS final rule here. Additional information on the rule can be found in the OPPS Press Release, OPPS Fact Sheet, and Transparency Fact Sheet. Look for updates from ACC Advocacy staff on ACC.org/Advocacy and in upcoming issues of The Advocate newsletter.

Clinical Topics: Cardiovascular Care Team, Invasive Cardiovascular Angiography and Intervention, Noninvasive Imaging, Interventions and Imaging, Computed Tomography, Echocardiography/Ultrasound, Nuclear Imaging

Keywords: Tomography, Radiation Dosage, Ultrasonography, Interventional, Positron-Emission Tomography, Prospective Payment System, Policy, Cardiology, Tomography Scanners, X-Ray Computed, Medicare, Percutaneous Coronary Intervention, Feedback, Quality Indicators, Health Care, Mandatory Reporting, Fractional Flow Reserve, Myocardial, Centers for Medicare and Medicaid Services, U.S., Cardiac Rehabilitation, Outpatients, ACC Advocacy

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