Our colleagues will be providing a complete analysis of the rules in their upcoming webconference, but there are two items in the proposal that we expect will have a significant impact on CV leaders.
1. CMS proposes to allow PCI in ASCs
In last year's 2019 Hospital Outpatient Prospective Payment System (HOPPS) final rule, CMS added 12 diagnostic cath codes and five supplemental codes to its ASC covered surgical procedures list for the first time. In the past, CMS did not allow caths in ASCs due to safety concerns, but as procedures have become safer CMS re-evaluated its position.
In the 2020 proposed rule, CMS is doubling down by expanding to some PCI procedures. Specifically, CMS is proposing to update the list of ASC covered surgical procedures by adding three coronary intervention procedures:
- Percutaneous transluminal coronary angioplasty (CPT 92920, 92921);
- Percutaneous transcatheter placement of intracoronary stent(s), with coronary angioplasty when performed (CPT 92928, 92929); and
- Percutaneous transcatheter placement of drug eluting intracoronary stent(s), with coronary angioplasty when performed (CPT C9600, C9601).
In its commentary, CMS reviewed clinical characteristics and consulted clinical advisors to conclude that these procedures can be safely performed in ASCs and would not pose a significant safety risk to patients.
As part of its evaluation, CMS also reviewed other coronary interventions—including coronary atherectomy, percutaneous transluminal revascularization of or through coronary artery bypass graft, and revascularization of chronic total occlusion (CTO)—which it will not include in the ASC-covered procedure list for 2020, but the agency is soliciting public comments on whether these should be added in the future.
2. CMS will require hospitals to publicly display payer-specific negotiated charges for 300 'shoppable services'—including CV services
CMS is proposing to require hospital websites to prominently display payer-specific negotiated charges for at least 300 "shoppable services"—a term CMS defines "as a service that can be scheduled by a health care consumer in advance." CMS would designate 70 of the service charges that must be included in the list, and the hospital would have to choose the remaining 230. Under the proposal, hospitals that do not comply with the regulations could face a monetary penalty of up to $300 per day until they are in compliance or provide a corrective action plan.
Our colleagues reviewed this change in more detail in this blog post, but we specifically wanted to highlight what CV leaders need to know. What will likely stand out to all providers is the inclusion of "new patient office or other outpatient visit" (CPT 99203, 99204, 99205) and "patient office consultation" (CPT 99243, 99244) in the 70 services CMS would designate all hospitals must include on the list of publically available charge information. In addition, CMS has selected a few CV-specific codes, including:
- Electrocardiogram (EKG), routine, with interpretation and report (CPT 93000);
- Insertion of catheter into left heart for diagnosis (CPT 93452); and
- Cardiac valve and other major cardiothoracic procedures with cardiac catheterization with major complications or comorbidities (DRG 216).
While those are the CV services CMS would require all hospitals to include, individual hospitals are likely to select other "shoppable" CV services to include as part of the 230 additional self-selected codes, such as echocardiogram, cardiac CT, or additional diagnostic cath codes.
CMS is seeking public comments on the 70 CMS-selected shoppable services and feedback on whether they should consider more or less than the proposed 300 services total. Stay tuned to hear public commentary and how CMS decides to move forward in the 2020 outpatient final rule expected this fall.
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