CMS backs off some burdensome proposals but imposes negative payment update in latest rule

December 23rd, 2015

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains how CMS revised parts of the 2016 OPPS final rule, including updates to comprehensive APC policy, observation-related packaging, add-on code evaluation, and payment-rate changes. It is aimed at hospital outpatient billing, APC, and Medicare reimbursement professionals who need to understand how the final rule affects payment structure and operational processes. The discussion stays at a high level while pointing to the types of APC and OPPS guidance addressed in the rule.

Why This Topic Matters

The rule affects hospital outpatient reimbursement, packaged payment behavior, and the way certain services are grouped under APC methodology. It also highlights a payment-rate reduction tied to CMS’s prior estimation error, which is important for financial planning and billing workflow awareness.

Article Sections

  1. CMS revises comprehensive APC policy for 2016

    This section summarizes the addition of new comprehensive APCs and the related updates CMS made in the final rule. It also introduces the broader context of outpatient payment methodology changes for the year.

  2. Observation-related comprehensive APC update

    This section focuses on the observation services APC and the types of claims components CMS used for the final policy. It also describes the operational impact of the new framework for outpatient claims review.

  3. Complexity adjustments and add-on codes

    This section covers CMS’s expansion of the set of add-on codes considered for complexity adjustment. It places that change within the larger comprehensive APC framework.

  4. Negative payment update in the 2016 OPPS final rule

    This section explains the payment-rate reduction in the outpatient prospective payment system and the reason CMS gave for the adjustment. It also notes the related quality reporting reduction discussed in the rule.

What You Will Learn

  • How CMS changed comprehensive APC policy in the 2016 OPPS final rule
  • What the article says about observation-related APC updates
  • How the final rule affects add-on code complexity evaluation
  • Why the OPPS payment update was negative in 2016
  • Which operational areas hospitals should review after the rule changes

Who Should Read This

  • Hospital outpatient billing staff
  • APC and OPPS reimbursement specialists
  • Revenue cycle managers
  • Coding compliance teams
  • Medicare policy analysts

Codes Discussed

  • HCPCS Level II: G0378
  • HCPCS Level II: G0379
  • HCPCS Level II: G0380
  • HCPCS Level II: G0463
  • HCPCS Level II: G0381
  • HCPCS Level II: G0382
  • HCPCS Level II: G0383
  • HCPCS Level II: G0384
  • CPT: 99281
  • CPT: 99284
  • CPT: 99285
  • CPT: 99291
  • CPT: 99282
  • CPT: 99283

Code Ranges Discussed

  • CPT: 99281-99284
  • HCPCS Level II: G0381-G0384

Modifiers Discussed

  • Unspecified: -CA

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