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The US Centers for Medicare and Medicaid Services (CMS) is pushing for an outpatient environment in which payments vary less according to who owns a facility, hospitals get a supervision break, and patients have access to clear information on how much they're being charged for items and services. All 3 concepts figure heavily into the proposed 2020 outpatient payment system (OPPS) rule.

The proposed rule, released July 29, would complete a 2-year CMS effort to move toward a "site neutral" payment model in its reimbursements for physician services, doing away with a system that pays so-called "off campus" hospital-owned facilities more than it does their independent equivalents. Payment for physical therapy services in outpatient settings are paid under the CMS physician fee schedule and so are not impacted by the OPPS site-neutral policies.

Other trends continue as well, including an APTA-supported move toward easing supervision burdens placed on hospitals. The proposed rule would change supervision requirements for outpatient therapeutic services in all hospitals from "direct" to "general," meaning that while a given procedure would be furnished under a physician's overall direction and control, the physician's physical presence no longer will be required during the performance of the procedure. The change is viewed as a particularly positive one for critical-access hospitals and other facilities in underserved areas.

A shift toward greater transparency also is reflected in the proposed rule, with CMS aiming to require hospitals to make their standard charges public for all items and services. These standard charge lists—a facility's gross and payer-negotiated charges for supplies, procedures, beds and food, practitioner services, and a host of other items—would also be required for a limited set of so-called "shoppable services" that can be scheduled by a consumer in advance. CMS puts teeth into the requirement through monetary penalties and publication of violations for facilities that don't comply.

Another trend APTA is watching: prior authorization, which in the proposed rule would be required for several cosmetic procedures including rhinoplasty. While this doesn't directly affect services associated with physical therapy, APTA advocates in general against prior authorization requirements that slow the delivery of care and limit patient access to appropriate interventions.

Also included in the proposed OPPS:

  • Payment rates for outpatient hospitals and ambulatory surgical centers (ASCs) would increase by 2.7%.
  • CMS is soliciting comments on adding 4 safety measures to the Outpatient Quality Reporting Program that have already been required of ASCs: patient falls, patient burns, wrong site/side/procedure/implant, and all-cause hospital transfers/admissions.

A CMS fact sheet on the proposed rule is available online. APTA is analyzing the proposed rule and will provide comments to CMS by the September 27 deadline.


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