CMS proposes massive APC reconfiguration, updates 2-midnight rule

August 19th, 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 reviews major proposals in the 2016 OPPS proposed rule, including broad APC reconfiguration, new comprehensive APC categories, observation-related payment changes, and updates to the 2-midnight rule. It is intended for hospital outpatient billing, reimbursement, and compliance professionals who need to assess operational and financial impact, track proposed status indicator changes, and understand the broader direction of CMS outpatient payment policy.

Why This Topic Matters

The proposed changes could materially affect outpatient payment structure, claim-level reimbursement, and review processes for providers. Readers responsible for coding, charge capture, revenue cycle, and compliance will want to understand which outpatient services may be affected and what operational preparation may be needed.

Article Sections

  1. APC reconfiguration

    Discusses CMS proposals to reorganize outpatient payment categories across multiple clinical families and to revise APC numbering and structure. The section also notes where proposed crosswalk and addendum resources are used to review the changes.

  2. New C-APCs

    Summarizes the proposed additions to comprehensive APCs and the broader observation-related framework discussed in the rule. It also covers the proposed reporting and claim-level implications tied to the expanded C-APC program.

  3. 2-midnight rule update

    Reviews the proposed outpatient discussion of short-stay inpatient admissions, medical review, and the shifting role of QIO entities in review activities. The section describes the policy direction and oversight framework at a high level.

  4. Additional 2016 OPPS changes proposed by CMS

    Covers other proposed outpatient payment policy changes beyond APC restructuring, including discontinued procedure payment adjustments and inpatient-only list movement. It also notes related status indicator proposals for selected procedures.

What You Will Learn

  • How CMS is proposing to restructure outpatient APC groupings for 2016
  • What categories of outpatient services are affected by the proposed APC consolidation
  • How the proposed comprehensive APC expansion changes the outpatient payment landscape
  • What the article says about observation-related payment policy and claim review
  • How the proposed 2-midnight rule update changes short-stay review oversight
  • What other OPPS policy changes are being proposed for 2016

Who Should Read This

  • Hospital outpatient coders
  • Reimbursement and revenue cycle staff
  • Compliance officers
  • Outpatient billing managers
  • Healthcare consultants
  • CDI and auditing professionals

Codes Discussed

  • HCPCS Level II: G0378
  • HCPCS Level II: G0379
  • CPT: 99284
  • CPT: 99285
  • HCPCS Level II: G0384
  • CPT: 99291
  • HCPCS Level II: G0463
  • Unspecified: 0312T
  • Unspecified: 20936
  • Unspecified: 20937
  • Unspecified: 20938
  • Unspecified: 22552
  • Unspecified: 54411
  • Unspecified: 54417

Code Ranges Discussed

  • CPT: 99291

Modifiers Discussed

  • Unspecified: -52
  • Unspecified: -73
  • Unspecified: -74

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