The ACC submitted a letter this week to the Centers for Medicare and Medicaid Services (CMS) with comments on proposed updates to the 2018 Hospital Outpatient Prospective Payment System (OPPS).

The ACC's comments specifically supported the reinstatement of the notice of nonenforcement of the direct supervision instruction for outpatient therapeutic services for critical access hospitals and small rural hospitals having 100 or fewer beds in 2018 and 2019. The College's comments also recommended changes to the proposed Imaging Ambulatory Payment Classification (APC) structure for 2018 in order to maintain payment stability for cardiovascular imaging services, as well as a recommendation for the addition of acute myocardial infarction, percutaneous coronary intervention (AMI-PCI) cases reported by CPT code 92941 to the Inpatient Only List.

Proposed changes to the Hospital Outpatient Quality Reporting (OQR) Program were also addressed in the comment letter. The letter urges CMS to ensure that social risk factors do not undermine evidence-based measures in the determination of quality care and encourages the Agency to align any efforts to incorporate social risk factors in the program with similar efforts already underway in other Medicare payment programs. The ACC also requests CMS continue to consider both the potential limitations in data collection in accounting for social risk factors, as well as the impact of socioeconomic data collection on the patient. The letter encourages CMS to support Medicare beneficiaries seeking care by engaging patients and social support networks in meaningful education on how the collection of this data is utilized to improve care.

"The College encourages CMS to maintain a transparent process for engaging stakeholder feedback through future rulemaking and utilization of this panel. As CMS makes updates to the OPPS, the College asks that the Agency continue to prioritize policies that provide a stable environment for patient access to high-quality, evidence-based cardiovascular care," writes ACC President Mary Norine Walsh, MD, FACC.

Keywords: Current Procedural Terminology, Outpatients, Hospitals, Rural, Centers for Medicare and Medicaid Services, U.S., Inpatients, Risk Factors, Medicare, Medicaid, Ambulatory Care, Prospective Payment System, Percutaneous Coronary Intervention

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