Wow, the last couple weeks have been busy, considering the 2014 Outpatient Prospective Payment System (OPPS) proposed rules . Every year CMS publishes an OPPS proposed rule with a 60 day comment period, giving affected parties a chance to review it. CMS includes descriptions of changes to grouping logic, updated packaging policies, modifications to payment rules, and other pertinent topics affecting OPPS. The final rule is usually published on or about November 1st. The 2014 proposed rule was published July 8th with a comment period set for September 6th. This rule represents the largest change in hospital payment since OPPS was introduced in August 2000.
On August 26th and 27th CMS held the annual fall Advisory Panel Meeting on Hospital Outpatient Payments (HOP Panel). It was a very interesting meeting as many testified about the potential financial impact of the proposed rule. Many touched on the fact that the tables published with the rule in July were inconsistent. With these conflicting tables and the magnitude of the changes, no one had been able to replicate the rule to predict the potential impact to providers.
A number of hospital representatives testified. All of them were members of the Provider Roundtable (PRT). All commented on the impact the proposed rule would have, specifically noting the inability to project impact as a hardship, and asked the panel to recommend a delay and correction of the errors.
Hospital representatives also noted that very few written comments had been received.
It is disappointing that more hospitals aren’t engaged and participating in the forum. Participation in the forum has been demonstrated to have an impact in the rule-making process. Basically, the PRT is the only representative of the hospital community.
Then on August 28, two days after the HOP Panel meeting, CMS published updated tables for the OPPS.
Additional corrections to the rule were published in the Federal Register on September 6th, which also included an extension of the comment period. You can find it at the US GPO website.
So, a lot has been going on with the 2014 OPPS proposed rule in the last few weeks. Please stay tuned and do your best to be involved. Read the rule and review the impact on your hospital.
Dave Fee is the Outpatient Products Marketing Manager with 3M Health Information Systems.