You may have heard the recent buzz from the release of the 2017 proposed rules by CMS. The proposed rules were published on July 7, and the comment period is open through September 6, 2016. The final rules for 2017 will be available in November. While these changes are still in the proposal stage, they represent a relatively neutral change in overall reimbursement. Please contact RBS for further discussion of how these changes may affect your practice.
The changes affecting Radiation Oncology are summarized below:
Re-valuing of Reimbursement for Treatment Devices
It has been proposed by CMS that the relative value units for CPT codes for treatment devices , 77332-77334, should be reduced to reflect lower components for physician work. The reduction will lower professional reimbursement for treatment devices by approximately 5%. The overall affect will be a $20 - $40 decrease in the reimbursement for a typical course of treatment.
Separate Technical and Professional Codes for CPT code 77470 Special Treatment Procedure
Code 77470 is billable in cases such as concurrent chemotherapy which require additional work and coordination with other providers and staff. This code was flagged by CMS as a high expenditure for the specialty. The RUC recommended a reduction in the work RVU for CPT code 77470. This change would lower reimbursement for professional billing of this code by around 2% or under $5 per unit. However, CMS is also seeking comments regarding the suggestion to replace this global code with two separate CPT codes - one temporary “G code” which would represent the physician’s professional billing and a separate “G code” which would represent the facility or technical work associated with the code.
Work RVUs for Interstitial Radiation Application
It was proposed by the RUC that work RVUs for CPT code 77778 for interstitial radiation application should be increased from 8.0 to 8.78. CMS is proposing to retain the current RVU of 8.0 (thus, not allowing for an approximate 7% increase to the overall reimbursement for this code.) Additionally, CMS will maintain a work RVU of 0 for CPT code 77790, handling and loading of radiation source.
Site Neutral Payment Provisions
CMS has proposed that services rendered at certain provider based departments (PBDs) will no longer be billable under HOPPS but will instead be moved to MPFS or free-standing billing. Any hospital-owned PBDs that were billing under HOPPS prior to November 2, 2015, will be grandfathered in or excepted and may continue to bill under HOPPS. Additionally, PBDs that are within 250 yards of a remote location of the department can continue to be billed under HOPPS. It has been proposed that all other provider based departments will be moved to free-standing billing in 2017 under Medicare Part B, and providers will be paid at those locations under the non-facility MPFS rates. Further details on this topic can be found on the CMS Website under the 2016 Fact Sheet.
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