Outpatient hospitals and ambulatory surgical centers (ASCs) would face fewer location-based payment discrepancies under proposed payment policy changes for calendar year (CY) 2017. CMS proposed payment updates for the hospital outpatient prospective payment system (OPPS) and ASC payment system in Proposed rule, with an accompanying fact sheet, that also addresses section 603 of the Bipartisan Budget Act of 2015 (P.L. 114-74), flexibility in the Medicare electronic health records (EHR) Incentive Program, new quality reporting measures, and physicians’ concerns about pain management. Comments are due to CMS by September 6 (Proposed rule, 81 FR 45603, July 14, 2016).
The Proposed rule does not address off-campus provider-based departments that were in the process of being built on November 2, 2015, the date of enactment of the Bipartisan Budget Act, and therefore are not qualified to be excepted as a grandfathered facility (see Provider-based billing moratorium concerns? CMS wants to hear them, April 26, 2016). There is pending legislation, H.R. 5273, that would account for these "mid-build" facilities by allowing them to be grandfathered into the OPPS rates (see Lawmakers lend hospitals helping hand to improve patient care, May 19, 2016).
In a recent Proposed rule for updates to the physician fee schedule (81 FR 28162, May 9, 2016), CMS set forth a plan to streamline EHR reporting requirements to allow additional flexibility and improved patient outcomes (see Physician reporting streamlined, less burdensome under flexible Quality Payment Program, April 28, 2016). Under this Proposed rule, the agency took similar steps for hospitals participating in the EHR Incentive Program by decreasing the reporting period from a full calendar year to 90 days for returning participants, as well as accommodations for new participants and hardship exemptions.
For Wolters Kluwer’s full analysis of the Proposed rule, see Patient-focused and physician-supporting changes proposed for OPPS and ASCs, July 13, 2016.
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