Hospital Outpatient and Ambulatory Surgery Center Payment System Proposed Rule

Of note, no electrophysiology procedures were added to the covered procedure list for ASCs.

• 2024 Payment Update. CMS proposes to increase hospital outpatient payments by 2.8%. CMS is able to provide this increase because of the formula set out in federal statute which incorporates the inflationary costs of delivering health care. This statutory inflationary component to the formula does not exist in the Medicare Physician Fee Schedule.
• Inpatient Only (IPO) List. Medicare maintains what it calls the "inpatient only list," which is a list of services that CMS restricts payment for to the hospital inpatient setting.  CMS regularly revises the list, and this year plans to add several new CPT codes to the list, but makes no proposals to remove any codes from the list.
• ASC Covered Procedure List (CPL). In addition to its regular review of the IPO list, CMS annually reviews the ASC covered procedure list (CPL), a list of services for which CMS will make payment in the ASC setting only if the procedure is on the CPL. While being on the list does not restrict payment to the ASC setting, it is a requirement for payment when the service does happen to be delivered in an ASC. While CMS has received several requests over the last few years to add moreelectrophysiology procedures to the CPL, CMS made no proposals to do so this year and focuses only on the addition of dental procedures.
• Hospital Price Transparency Requirements. Over the last several years, CMS has issued regulations directed at increasing price transparency for services delivered in the hospital setting. Hospitals are required to post "standard charges" for items and services delivered in the hospital. CMS defines these "standard charges" in multiple ways and hospitals are required to post information regarding all of the following:
  • The chargemaster rate
  • The discounted cash price
  • Payer-specific negotiated charges
  • De-identified minimum and maximum negotiated charges

CMS is making several changes to the requirements, including proposals designed to increase hospital compliance with these obligations. More information on these proposals can be found in a CMS fact sheet focused solely on these provisions.