Coverage for Ablations in ASCs Not Included in OPPS/ASC Proposed Rule
On July 10th, the Centers for Medicare & Medicaid Services (CMS) published proposed rules for the Medicare Physician Fee Schedule (MPFS), and the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) services for calendar year (CY) 2025.
In the OPPS/ASC proposed rule, CMS did not propose to add cardiac ablation codes to the ASC Covered Procedures List (CPL) as requested. HRS will continue to advocate for the codes to be included in the CPL for CY 2025. CMS proposes to update payment rates for outpatient hospitals that meet applicable quality reporting requirements by 2.6%. The same update factor would apply to ASC payment rates for those ASCs that fulfil relevant quality metrics. CMS also proposes to establish device pass-through status for the PulseSelect™ Pulsed Field Ablation (PFA) System and the Aveir™ DR Dual Chamber Leadless Pacemaker System. In March, HRS sent a letter to CMS urging the agency to consider device pass-through status for dual chamber leadless pacemakers under the OPPS until permanent pricing and policies are established. Addition of the dual chamber leadless pacemaker codes to the ASC Covered Procedures List (CPL) is also proposed.
In the MPFS proposed rule, CMS estimates a conversion factor of $32.3562 for CY 2025, down approximately 2.8% from the CY 2024 conversion factor of $33.2875. The reduction is due to the expiration of the 2.93% increase provided by Congress to the CY 2024 fee schedule, plus a positive budget neutrality adjustment of 0.05% triggered by CY 2025 policies. As part of the proposals, CMS is addressing global surgical payment policy by emphasizing the use of transfer of care modifiers "for all 90-day global surgical packages in any case when a practitioner plans to furnish only a portion of a global package (including but not limited to when there is a formal, documented transfer of care as under current policy, or an informal, non-documented but expected, transfer of care)." CMS also proposes a new E/M add-on code for use by practitioners who did not perform the procedure (i.e., did not bill the global code) for related post-procedure care. CMS proposes further changes to telehealth services that would allow use of two-way, real-time audio-only communication technology for service furnished to a patient in their home if the patient is not capable of, or does not consent to, the use of video technology.
In addition to the payment policies, the MPFS proposed rule would make several changes to the Quality Payment Program (QPP), including the Merit-Based Incentive Payment System (MIPS). CMS has also included a Request for Information on "Building upon the MIPS Value Pathways (MVPs) Framework to Improve Ambulatory Specialty Care."
CMS will accept comments on both proposed rules until September 9th. HRS will continue to review the rules and provide detailed summaries in the coming weeks.