12/7/2017 OVERVIEW. CPAs & ADVISORS
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1 CPAs & ADVISORS experience perspective // CY 2018 OPPS/ASC FINAL RULE & OTHER HEALTHCARE REGULATORY UPDATES Michael K. Westerfield, CPA, FHFMA OVERVIEW CY 2018 OPPC/ ASC Final Rule OPPS payment update MRI and CT cost allocations 340B Program s Updates to Inpatient Only (IPO) List Outpatient Quality Reporting (OQR) Program Other items CY 2018 Medicare Physician Fee Schedule OIG 2018 Work Plan New areas of focus Continuing areas of OIG interest 2 // experience perspective 1
2 CY 2018 OPPS/ ASC FINAL RULE Increase in OPPS payments Market Basket Increase 2.70% Less: Multi-factor Productivity Adjustment 0.60% Less: Adjustment Required ACA 0.75% Actual Rate Update 1.35% 3 // experience perspective CY 2018 OPPS/ ASC FINAL RULE T op 5 Largest Negative Impacts - By Percentage and Dollar Provider Estimated 2017 Estimated 2018 Estimate d $ Estimated % A $78,562,976 $74,538,633 -$4,024, % B $35,894,492 $34,558,500 -$1,335, % C $45,728,590 $44,453,689 -$1,274, % D $1,716,946 $1,683,772 -$33, % 4 // experience perspective 2
3 CY 2018 OPPS/ ASC FINAL RULE T op 5 Largest Positive Impacts - By Percentage Provider Estimated 2017 Estimated 2018 Estimated $ Estimated % Z $7,876,204 $8,590,822 $714, % Y $2,337,830 $2,548,394 $210, % X $7,822,970 $8,486,152 $663, % W $8,513,374 $9,131,211 $617, % Z $22,154,125 $23,684,430 $1,530, % T op 5 Largest Positive Impacts - By Dollar Provider Estimated 2017 Estimated 2018 Estimated $ Estimated % 1 $49,128,173 $52,245,300 $3,117, % 2 $42,210,300 $45,090,319 $2,880, % 3 $38,281,103 $40,261,876 $1,980, % 4 $22,154,125 $23,684,430 $1,530, % 5 $24,663,283 $26,071,518 $1,408, % 5 // experience perspective MRI and CT cost allocation methodologies Square footage vs. direct allocation or dollar value Salaries? 6 // experience perspective 3
4 340B Program s Reducing payment to Average Sales Price (ASP) less 22.5% This is compared to current rate of ASP plus 6% Formulary based on MedPAC s estimate 7 // experience perspective // Updates to Inpatient Only (IPO) List A) Are most outpatient departments equipped to provide the services? B) Can the simplest procedure described by the HCPCS/CPT code proposed for elimination be performed by most outpatient departments? C) Is the procedure related to previously removed codes? D) Are many hospitals performing the procedure in outpatient settings? E) Can the procedure be performed safely in an ambulatory surgery center, is the procedure on the ambulatory surgery center list of approved procedures, or is the procedure proposed for inclusion on that list? 8 // experience perspective 4
5 // Updates to Inpatient Only (IPO) List - Continued 9 // experience perspective // Updates to Inpatient Only (IPO) List - Continued 10 // experience perspective 5
6 Hospital Outpatient Quality Reporting (OQR) Program: s for CY 2020, 2021, and 2022 Payment Determinations and Subsequent Years Outpatient hospitals are subject to a reduction of 2.0% for failure to meet requirements s to program measures Estimated burden reduction of 457,490 hours 11 // experience perspective Hospital OQR measures to be removed: OP-1: Median Time to Fibrinolysis OP-4: Aspirin at Arrival OP-20: Door to Diagnostic Evaluation by a Qualified Medical Professional OP-25: Safe Surgery Checklist Use OP 26: Hospital Outpatient Volume Data on Selected Outpatient Surgical Procedures 12 // experience perspective 6
7 Ambulatory Surgical Center Quality Reporting (ASCQR) measures to be removed: ASC-5: Prophylactic Intravenous (IV) Antibiotic Timing; ASC-6: Safe Surgery Checklist Use; ASC-7: Ambulatory Surgical Center Facility Volume Data on Selected Ambulatory Surgical Center Surgical Procedures. 13 // experience perspective Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) Delayed for CY // experience perspective 7
8 Supervision of Hospital Outpatient Therapeutic Services Device Pass-Through Payment Comprehensive Ambulatory Payment Classifications (C-APCs) 15 // experience perspective CY 2018 MEDICARE PHYSICIAN FEE SCHEDULE CMS estimates a 0.41% increase in physician payment rates Reduced rates for off-campus departments from 50% to 40% percent New codes for Medicare telehealth services New Care Coordination Services and Payment for Rural Health Clinics (RHCs) and Federally-Qualified Health Centers (FQHCs) 16 // experience perspective 8
9 OIG 2018 WORK PLAN Significant New Audit Activities or revisions since January 2017 Medicare payments for unallowable overlapping hospice claims and part B claims Nationwide Medicare electronic health record incentive payments to hospitals Security of certified electronic health record technology under meaningful use Review of Medicare payments for bariatric surgeries Opioids in Medicaid Specialty drug coverage and reimbursement in Medicaid Review of hospital wage data used to calculate Medicare payments 17 // experience perspective OIG 2018 WORK PLAN CONTINUED Continuing Audit Activities Medical assistance days claimed by hospitals Reconciliations of outlier payments Comparison of provider based and free standing clinics Payment credits for replaced medical devices that were implanted Duplicate GME payments 18 // experience perspective 9
10 QUESTIONS & CONTACT INFORMATION Michael Westerfield, FHFMA, CPA Senior Manager BKD, LLP // experience perspective 10
Our comments focus on the following components of the proposed rule: - Site Neutral Payments,
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