September 2015

The ATS recently submitted comments on two CMS proposed rules that impact pulmonary, critical care and sleep medicine practitioners.  The first rule, known as the Hospital Outpatients Prospective Payment Rule, covers Medicare reimbursement and policies for outpatient services.  The ATS comments on this rule covered a range of topics including:

• APC Consolidation
• Proposed OPPS Treatment of New CPT and Level II HCPCS Codes
• Lung Cancer Screening – Shared Decision Making Visit Coding
• Device Payment Pass-Through Decision Transparency
• Chronic Care Codes
• Pulmonary Rehabilitation/Respiratory Therapy
• C-APCs Critical Care

The second comments submitted by ATS covered the Medicare Physician Fee Schedule, which addresses payments and policies for office-based physician services and other Medicare B providers.  The ATS comments covered several issues including:

• Potentially Misvalued Services under the Physician Fee Schedule
• Practice Expense and Malpractice Expense Values for Pulmonary Procedures
• EBUS RUC work values (HCPCS 3160A, 3160B, 3160C)
• Elimination of Refinement Panels
• Advance Care Planning Services
• Complex Chronic Care Codes
• Lung Cancer Screening – Shared Decision Making Visit Coding
• Quality Measures