July 20, 2021, the Centers for Medicare and Medicaid Services released the CY 2022 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule. Key provisions of the proposal include the following:
Proposal to use CY 2019 claims data to set the CY 2022 OPPS and ASC payment rates due to the CY 2020 impact of the Covid-19 Public Health Emergency.
Using the hospital market basket methodology, for CY 2022, CMS proposes to increase payment rates under the ASC payment system by 2.3 percent for ASCs that meet the quality reporting requirements under the ASCQR Program. (This proposed increase is based on a hospital market basket percentage increase of 2.5 percent reduced by a proposed productivity adjustment of 0.2 percentage point.)
Proposal to re-adopt the ASC Covered Procedures List (CPL) criteria that were in effect in CY 2020 and to remove 258 of the 267 procedures that were added to the ASC CPL in CY 2021.
Changes to the Inpatient Only (IPO) List: CMS proposes to halt the elimination of the IPO list and, after clinical review of the services removed from the IPO list in CY 2021 propose to add the 298 services removed from the IPO list in CY 2021 back to the IPO list beginning in CY 2022. CMS is also proposing to codify in regulation the five longstanding criteria used to determine whether a procedure or service should be removed from the IPO list.
Device Pass-Through Payment Applications: Of the eight applications received for device passthrough payments, one of the applications (the Shockwave C2 Coronary Intravascular Lithotripsy (IVL) catheter) received preliminary approval for passthrough payment status through CMS quarterly review process. Comment is being sought on all eight applications.
ASCQR Program Proposal: CMS proposes changes for the CY 2024, CY 2025, and CY 2026 payment determinations and subsequent years. Proposed Measures include:
Adopt the COVID-19 Vaccination Coverage Among HCP measure beginning with the CY 2024 payment determination;
Resume data collection for four measures beginning with the CY 2025 payment determination: (a) ASC-1: Patient Burn; (b) ASC-2: Patient Fall; (c) ASC-3: Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant; and (d) ASC-4: All-Cause Hospital Transfer/Admission;
Require the ASC-11: Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery measure beginning with the CY 2025 payment determination; and
Require the ASC-15a-e: OAS CAHPS Survey-based measures with voluntary reporting beginning with the CY 2023 reporting period and mandatory reporting beginning with the CY 2024 reporting period/CY 2026 payment determination. In addition, CMS is proposing data submission requirements for the OAS CAHPS Survey-based measures and the COVID-19 Vaccination Coverage Among HCP measure.
Hospital Price Transparency increase penalties for noncompliance.
CMS is actively seeking comment on the CY 2022 Proposed Rule with final ruling expected in the fall of 2021.
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
“They are us and we are them. National's approach since being with us has been as a partner or better yet a family who cares about our success and does everything in its power to assist us in being successful."
DIRECTOR OF NURSING | LOS ALAMITOS, CALIFORNIA
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
"National Medical’s coding audit identified that our previous billing partner was coding and billing our ASC claims improperly. We were actually losing money on some cases because costly implant charges were not being coded and billed correctly. National Medical was able to go back and capture significant lost revenue. Their specialized, ASC expert coders have maximized our revenue and compliance."
MEDICAL DIRECTOR | CLEVELAND, OHIO
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
“I can already tell the difference in the quality of work compared to our previous billing company. The responses and willingness to help us be successful shows in how fast we receive a response, resolution and the wealth of knowledge you share with us. Thank you!”
ASC ADMINISTRATOR | FREMONT, CA
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
"National Medical’s expertise in the ASC market revealed that our contracts were reimbursing less than Medicare and in some cases only 38% of Medicare. Due to their expertise and experience, they were able to renegotiate better contracts and increase our contract reimbursement by 305%. We’re now able to bring additional cases to our center."
ASC ADMINISTRATOR | BALTIMORE, MARYLAND
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
"Before we hired National Medical, we were handing billing in house and were averaging $811 for each surgery. In our very first year with National Medical, with the same number of cases, we have increased our cash per case to $1,400. That represents an increase of approximately $600 per case, or 73 percent, all of which is pure profit for us. In absolute terms, that means an additional $90,000 per month to us on the same number of cases."
OWNER AND CEO, SURGERY CENTER | BAKERSFIELD, CALIFORNIA
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
“We have not second guessed our decision to switch billing companies once since transitioning to National Medical. Their team seems to remind us constantly why it was such a good decision!
ASC ADMINISTRATOR | SOUTHLAKE, TX
Our clients are typically bold, ambitious leaders within the surgery market. They share our passion for results and are prepared to act decisively to achieve them.
Read below to see what our clients think about us and our performance. And we highly encourage you to speak with them so that you can hear it first hand.
"National Medical consistently exceeds our expectations by going above and beyond every day. Their team is proactive, highly attentive and smart. To top it off, their detailed analytics team provides us with powerful insights into our business, allowing us to make informed decisions. In short, they are the perfect partner for all of our revenue cycle needs."
CHIEF OPERATING OFFICER, SURGERY CENTER | PORTLAND, OREGON