A separate Medicare proposal to package more than 280 physician services, including more than 80 pathology physician services, under the Hospital Outpatient Prospective Payment System (OPPS) has also come under fire from industry groups. CMS proposed the new bundling policies as part of changes to the OPPS for 2014. The proposal was announced July 8 and published in the July 19 Federal Register. Essentially, CMS is proposing three packaging policies: packaging physician pathology services into “primary procedures,” packaging certain “add-on” codes, and packaging nearly all clinical diagnostic laboratory tests (except molecular pathology). In comments submitted to CMS, the College of American Pathologists (CAP) notes that CMS has proposed this untested expansion of the OPPS packages without taking necessary steps to define the proposal in detail, engage with stakeholders to understand the impact of the proposal on affected groups, and anticipate possible consequences that could adversely affect the quality of care. “Further, CMS’s justification for the proposal—that additional packaging will reduce incentives to overutilize services or provide services that are not medically necessary—carries an equal risk of creating incentives to reduce use of medically necessary services in ways that are detrimental to the quality of care,” says CAP. “As pathology practices […]
A separate Medicare proposal to package more than 280 physician services, including more than 80 pathology physician services, under the Hospital Outpatient Prospective Payment System (OPPS) has also come under fire from industry groups.
CMS proposed the new bundling policies as part of changes to the OPPS for 2014. The proposal was announced July 8 and published in the July 19 Federal Register.
Essentially, CMS is proposing three packaging policies: packaging physician pathology services into “primary procedures,” packaging certain “add-on” codes, and packaging nearly all clinical diagnostic laboratory tests (except molecular pathology).
In comments submitted to CMS, the College of American Pathologists (CAP) notes that CMS has proposed this untested expansion of the OPPS packages without taking necessary steps to define the proposal in detail, engage with stakeholders to understand the impact of the proposal on affected groups, and anticipate possible consequences that could adversely affect the quality of care.
“Further, CMS’s justification for the proposal—that additional packaging will reduce incentives to overutilize services or provide services that are not medically necessary—carries an equal risk of creating incentives to reduce use of medically necessary services in ways that are detrimental to the quality of care,” says CAP. “As pathology practices may receive referrals of specimens from multiple hospitals and physician practices, keeping track of when tests should be paid separately vs. packaged into a hospital service will create enormous administrative burdens.”
CAP also notes that CMS plans to package nearly all clinical diagnostic laboratory tests (with the exception of molecular pathology) unconditionally into a “wide array of primary services provided in the hospital outpatient setting” include limited information on the primary services that would be subject to the packaging rule.
“The proposal is remarkably broad, and therefore has a very substantial potential to impact the reimbursement of laboratory tests, since it involves 1,096 laboratory tests,” says CAP.
“This proposal encompasses the entire clinical laboratory fee schedule, and therefore there must be an impact upon providers of these services, namely pathologists and the clinical laboratory industry. CMS provides no such impact analysis in this proposal, and CAP questions exactly how these codes will be packaged under the proposal.”
Even with a more transparent process for OPPS packaging and grouping proposals, bundling services remains a relatively new concept for most providers, particularly pathologists, notes CAP. Evidence supporting these types of arrangements has been narrowly focused on a limited number of procedural episodes of specific types of integrated care arrangements.
“Instead of devoting limited resources to implement untested bundling proposals on a national level, CMS should focus more attention on the Innovation Center’s efforts to test bundled payment and other new models of payment,” urges CAP in its comments.
Takeaway: Industry groups are urging CMS to scrap a recent proposal to package certain pathology services and laboratory tests under the Hospital Outpatient Prospective Payment System.
