Initial Review of finalized HOPPS Rule

On November 1, 2017, CMS released CY2018 Hospital Outpatient Prospective Payment System (HOPPS) Final Rule. ASE is currently reviewing the details of the policy and payment modifications contained in the rule and will provide a more extensive summary soon. The HOPPS final rule will be published in the Federal Register on November 13, 2017, however it can be downloaded here.

This final rule with comment period revises the Medicare hospital outpatient prospective payment system for CY 2018 to implement changes arising from CMS’ continuing experience with these systems and certain provisions under the 21st Century Cures Act. In this final rule with comment period, CMS describes the changes to the amounts and factors used to determine the payment rates for Medicare services paid under the OPPS payment system.

This final rule with comment period will become effective on January 1, 2018. CMS will accept comments on this no later than 5 PM EST on December 31, 2017.
• OPPS Conversion Factor: CMS proposes a CY 2018 conversion factor of $78.636. This change is based on the projected hospital market basket increase of 2.7 percent minus both a 0.6 percentage point adjustment for multi-factor productivity and a 0.75 percentage point adjustment required by law. The effective update is 1.35 percent.
• Payment for hospital outpatient contrast-enhanced echocardiography: The 2018 proposed rule HOPPS rule this year again included significant restructuring of Ambulatory Payment Classifications (APCs) for imaging services and consolidating several APCs. CMS proposed adjustments to the APC to both non-contrast and contrast enhanced diagnostic imaging procedures. ASE, along with ACC and SCMR, met with CMS to request modifications to the structure of the proposed rule APCs.
The CY2018 proposed payment level represented a significant underpayment for contrast agents (ultrasound enhancing agents) and the costs for their administration with the rate for contrast echocardiography proposed at only $15 higher than unenhanced echocardiography. Thus, constructing an economic disincentive for hospital to use a high value, low cost, precision cardiac procedure.

We are pleased that CMS accepted the cardiology community’s proposals which continued the stabilization of echo reimbursement established in recent years and creates greater clinical homogeneity. Below is a chart highlighting the CY 2018 APC Payment rates for the most common echocardiography procedures.

2018 HOPPS Final Rule

Late this evening, CMS released CY2018 Hospital Outpatient Prospective Payment System (HOPD) Final Rule.   ASE is currently reviewing the details of the policy and payment modifications contained in the rule and will provide a more extensive summary soon.  The HOPD final rule will be published in the Federal Register on November 13, 2017, however it can be  downloaded here.

This final rule with comment period revises the Medicare hospital outpatient prospective payment system for CY 2018 to implement changes arising from CMS’ continuing experience with these systems and certain provisions under the 21st Century Cures Act.  In this final rule with comment period, CMS describes the changes to the amounts and factors used to determine the payment rates for Medicare services paid under the OPPS payment system.

This final rule with comment period will become effective on January 1, 2018.  CMS will accept comments on this later than 5 p.m. EST on December 31, 2017.

2018 Hospital Outpatient Prospective Payment Final Rule

• OPPS Conversion Factor: CMS proposes a CY 2018 conversion factor of $78.636. This change is based on the projected hospital market basket increase of 2.7 percent minus both a 0.6 percentage point adjustment for multi-factor productivity and a 0.75 percentage point adjustment required by law. The effective update is 1.35 percent.

• Payment for hospital outpatient contrast-enhanced echocardiography: The 2018 proposed rule HOPD rule this year again included significant restructuring of Ambulatory Payment Classifications (APCs) for imaging services and consolidating several APCs. CMS proposed adjustments to the APC to both non-contrast and contrast enhanced diagnostic imaging procedures. ASE, along with ACC and SCMR, met with CMS to request modifications to the structure of the proposed rule APCs.

The CY2018 proposed payment level represented a significant underpayment for contrast agents (ultrasound enhancing agents) and the costs for their administration with the rate for contrast echocardiography proposed at only $15 higher than unenhanced echocardiography.  Thus, constructing an economic disincentive for hospital to use a high value, low cost, precision cardiac procedure.

We are pleased that CMS accepted the cardiology community’s proposals which continued the stabilization of echo reimbursement established in recent years and creates greater clinical homogeneity.  Below is a chart highlighting the CY 2018 APC Payment rates for the most common echocardiography procedures.