Proposed OPPS Packaging Policy Would Include Packaging of Low-Level Drug Administration Services

According to CMS, data shows packaging drug administration services from APCs 5691 and 5692 makes sense from a cost and frequency of use perspective. 

This article was originally published on Revenue Cycle Advisor on August 14.

In a move that has been anticipated for a few years, CMS issued a proposal in the 2018 OPPS proposed rule to expand packaging policies to include low-level drug administration services.

This proposal would affect APC 5691 (Level 1 drug administration) and APC 5692 (Level 2 drug administration) when drug services for those APCs are reported with other separately payable services.

In the CY 2015 OPPS final rule, CMS created conditionally packaged payment for ancillary services assigned to APCs with a geometric cost of less than or equal to $100. The geometric mean costs for APCs 5691 (approximately $37) and 5692 (approximately $59) fall within that cost range. In addition, Medicare claims data from previous years shows services from these APCs are frequently reported on the same claim as other separately payable services. Therefore, CMS said in the proposed rule that bundling these services is appropriate at this time. Drug administration services reported by codes from APCs 5691 and 5692 would be separately payable when reported alone.    

The agency also said packaging these services will aid its goal of reducing payment differences between physician offices and hospital outpatient departments. Physicians are not eligible to receive payment for an office visit when a drug administration service is provided, but hospitals do receive separate payments for a clinic visit and drug administration services. By packaging these services, hospitals and physician offices will therefore receive payment for both the visit and the drug administration services.

The proposal would exclude packaging vaccine administration, as preventive services are excluded from packaging policies. It would also exclude drug administration add-on codes, although the agency is seeking comments on how to create an encounter-based payment approach for drug administration services reported by add-on codes.

Providers should review Addendum B of the proposed rule to note which codes would be affected by this change to packaging policies. In addition, providers should be aware that these codes still need to be reported even if the proposal is finalized, as data from claims including these codes will help set accurate payment rates for future years.

Comments on the proposed rule are due by September 11.