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.

 

 

 Comparison of CY2017 Final – CY2018 Proposed and Final HOPPS APC Rates for Echocardiography Services
CPT1/
HCPCS
Descriptor CY2017 Final      APC rate CY2018 Proposed APC rate CY2018 Final APC Rate Diff CY2017 to CY2018 $ Diff CY2017 to CY2018 %
Transthoracic Echocardiography
93303 Echo transthoracic $449.50 $472.98 $486.66 $37.16 8%
93304 Echo transthoracic $449.50 $472.98 $486.66 $37.16 8%
93306 Tte w/doppler complete $449.50 $472.98 $486.66 $37.16 8%
93307 Tte w/o doppler complete $449.50 $264.07 $486.66 $37.16 8%
93308 Tte f-up or lmtd $225.81 $264.07 $245.22 $19.41 9%
Transesophageal Echocardiography
93312 Echo transesophageal $449.50 $472.98 $486.66 $37.16 8%
93313 Echo transesophageal $449.50 $472.98 $486.66 $37.16 8%
93315 Echo transesophageal $449.50 $472.98 $486.66 $37.16 8%
93316 Echo transesophageal $225.81 $264.07 $486.66 $260.85 116%
93318 Echo transesophageal intraop $449.50 $472.98 $486.66 $37.16 8%
Stress Transthoracic Echocardiography
93350 Stress tte only $449.50 $472.98 $486.66 $37.16 8%
93351 Stress tte complete $449.50 $472.98 $486.66 $37.16 8%
Contrast Enhanced Echocardiography
C8921 TTE w or w/o fol w/cont, com $656.63 $487.72 $681.83 $25.20 4%
C8922 TTE w or w/o fol w/cont, f/u $656.63 $487.72 $681.83 $25.20 4%
C8923 2D TTE w or w/o fol w/con,co $656.63 $487.72 $681.83 $25.20 4%
C8924 2D TTE w or w/o fol w/con,fu $426.34 $339.14 $456.34 $30.00 7%
C8925 2D TEE w or w/o fol w/con,in $656.63 $487.72 $681.83 $25.20 4%
C8926 TEE w or w/o fol w/cont,cong $656.63 $487.72 $681.83 $25.20 4%
C8927 TEE w or w/o fol w/cont, mon $656.63 $487.72 $681.83 $25.20 4%
C8928 TTE w or w/o fol w/con,stres $656.63 $487.72 $681.83 $25.20 4%
C8929 TTE w or wo fol wcon,Doppler $656.63 $487.72 $681.83 $25.20 4%
C8930 TTE w or w/o contr, cont ECG $656.63 $487.72 $681.83 $25.20 4%

 

 

CMS finalized increase to echo code 93306 and accepted the cardiology community’s proposal that prevents cuts to echoes with contrast