Menu

CMS Proposes Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Changes for 2018

Health Care   |   November 14, 2017
Download   
Share Page

On July 13, 2017, the Centers of Medicare and Medicaid Services (“CMS”) released a proposed rule that would update the 2018 Hospital Outpatient Prospective Payment System (“OPPS”) and Ambulatory Surgical Center (“ASC”) Payment System.

Although hospitals would see a two percent (2%) Medicare reimbursement increase in 2018 for services paid under the OPPS, the proposed rule would change how Medicare pays hospitals for drugs that are acquired under the 340B Drug Discount Program and could potentially add certain procedures to be reimbursed on the ASC payable list.

Under the 340B Drug Discount Program, hospitals would be reimbursed separately for administering payable, non-pass-through drugs bought at a discount through the program at average sales price less 22.5% rather than the program’s average sales price plus 6%.

Additionally, two new spine procedures would be added to the ASC center payable list: cervical artificial disc arthroplasty and second-level cervical discectomy. As stated in the proposed rule, CMS is also soliciting comments regarding whether total knee arthroplasty, partial hip arthroplasty and total hip arthroplasty surgeries should take place at ASCs. This request for information has drawn speculation regarding CMS’ intentions to continue its mandatory, bundled-payment Comprehensive Care for Joint Replacement (“CJR”) program.

CMS will accept comments on the proposed rule and the request for information until September 11, 2017.

Reprinted with permission from The Florida Bar Health Law Section, November 2017 Health Law Update.


©2018 Carlton Fields Jorden Burt, P.A. Carlton Fields practices law in California through Carlton Fields Jorden Burt, LLP. Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our Contact Us form via the link below. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites.

Subscribe to Publications

Disclaimer

The information on this website is presented as a service for our clients and Internet users and is not intended to be legal advice, nor should you consider it as such. Although we welcome your inquiries, please keep in mind that merely contacting us will not establish an attorney-client relationship between us. Consequently, you should not convey any confidential information to us until a formal attorney-client relationship has been established. Please remember that electronic correspondence on the internet is not secure and that you should not include sensitive or confidential information in messages. With that in mind, we look forward to hearing from you.