The proposed rule for Hospital Outpatient Prospective Payment System (HOPPS) has been posted. Like all of the proposed payment policies, it’s massive and you need to read it yourself. CMS is proposing to “unbundle” “skin-substitutes” in the hospital outpatient setting. The impact will be complicated because that will change the way that the Ambulatory Payment Classifications are assigned. The same fixed rate has been proposed for all products at $125.38. CMS also proposes to delete the low tier codes. However, the fact is that the original calculations for package pricing in the HOPD were based on deeply flawed hospital data. The result was that most CTPs are too expensive for hospitals to afford and affordable products are limited to small sizes. Thus, large wounds can’t be treated with CTPs in the HOPD. This is a major reason that wound care (and CTPs) moved into the office based setting where there was no package pricing. As we all know, that created an entirely different set of problems and moral hazards.
CMS stated that the purpose of the new proposed policy is to limit some of the current profiteering practices occurring in this industry. CMS is making the payment consistent with the
physician office setting and has proposed to do away with the bundling of most CTPs in the hospital outpatient.
The good news is that Hospital outpatient departments and ambulatory clinics would receive a 2.4-percent payment boost next year (which includes a proposed 3.2% market basket update, offset by a 0.8 percentage point cut for productivity). Interestingly, hospitals will be requires to post real, consumer-usable prices and provide data in standardized formats that allow patients to understand what their care will actually cost. Hospitals that fail to comply could face civil monetary penalties.
I will try to post a better analysis of the impact of these proposals in the HOPD (hopefully provided by readers who understand this better than I do).
Resources:
- The proposed changes would help fix this problem: Price & Size Limits to Cellular Tissue Product (CTP) Use in the HOPD vs the Office (This is All So Messed Up) – Caroline Fife M.D.
- The Other Side of the CTP/Skin Substitute Story – How Poorly-Crafted CMS Policies for Package Pricing in HOPDs Created This Mess – Caroline Fife M.D.
- CMS Needs to Fix the Root Cause – the CTP/CAMP Payment Structure – Caroline Fife M.D.
- A Different Level of Thinking on Cellular Tissue Product Skin Substitute Policy – Caroline Fife M.D.
- (Not) Choosing Wisely for Cellular and/or Tissue-Based Products (CTPs) – Caroline Fife M.D.
