CMS considers eliminating inpatient-only list, expanding prior authorization

September 22nd, 2020

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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 summarizes key provisions in CMS’s 2021 outpatient hospital proposed rule and explains why hospitals, coders, and reimbursement staff should review it carefully. It focuses on broad policy changes affecting payment methodology, outpatient authorization requirements, supervision standards, and device-related updates, along with the article’s discussion of the implementation timeline and comment process.

Why This Topic Matters

The proposals could affect hospital billing workflows, outpatient service access, payment classification, and compliance planning for the 2021 calendar year and beyond. Stakeholders in hospital revenue cycle, coding, and reimbursement need to understand which services and policy areas are changing and when changes may take effect.

Article Sections

  1. Eliminating the inpatient-only list

    Discusses CMS’s proposal to phase out the inpatient-only list and the broader outpatient payment and review implications of removing procedures from that framework.

  2. 340B drug reimbursement updates

    Covers proposed updates to hospital reimbursement policy for drugs acquired through the 340B program and the related public comment issues.

  3. Prior authorization expansion

    Describes CMS’s planned expansion of outpatient prior authorization categories and the general types of services affected.

  4. Physician supervision requirements

    Summarizes proposed changes to supervision standards for outpatient therapeutic services and related flexibilities for certain settings and service types.

  5. Device pass-through updates

    Reviews the proposed device pass-through status updates, including the categories of devices under consideration and the agency’s request for comment.

  6. Additional information

    Provides references to supporting CMS material, comment timing, and publication notes.

What You Will Learn

  • The main outpatient hospital policy proposals included in the 2021 OPPS proposed rule
  • How CMS is approaching changes to site-neutral payment and outpatient reimbursement policy
  • Which broad outpatient service categories are affected by proposed prior authorization updates
  • What kinds of supervision policy changes CMS is proposing for outpatient therapeutic services
  • How device pass-through status is being updated in the proposed rule process

Who Should Read This

  • Hospital coders
  • Outpatient reimbursement staff
  • Revenue cycle professionals
  • Compliance teams
  • Health system administrators
  • Medical coding and billing educators

Codes Discussed

  • CPT: 22551
  • CPT: 22552
  • CPT: 63650
  • CPT: 63685
  • CPT: 63688
  • HCPCS Level II: C1734
  • HCPCS Level II: C1748
  • HCPCS Level II: C1823
  • HCPCS Level II: C1824
  • HCPCS Level II: C1839
  • HCPCS Level II: C1982
  • HCPCS Level II: C2596

Modifiers Discussed

  • HCPCS Level II: -TB

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