CMS Releases 2012 OPPS Proposed Rule
The Centers for Medicare & Medicaid Services (CMS) released the 2012 OPPS proposed rule late Friday afternoon, on the eve of the July 4th holiday weekend. The proposed rule does not contain many substantive operational changes. However, CMS does propose changes to some much discussed areas, including payment for combined CPT® codes for CT of the abdomen and pelvis and determining required levels of physician supervision.
“I was pleasantly surprised by several aspects of the rule,” says Jugna Shah, MPH, president of Nimitt Consulting Inc. based in Washington, DC. “First, I can’t recall the last time we had a file to read that was less than 1,000 pages. Second, CMS really listened to comments it received during the last year from many organizations on its rate-setting methodology for the ’new’ combined CT code for CT of the abdomen and CT of the pelvis.”
In 2011, the CPT editorial panel created three new codes for computed tomography (CT) of abdominal and pelvis:
- Code 74176, Computed tomography, abdomen and pelvis; without contrast material
- Code 74177, Computed tomography, abdomen and pelvis; with contrast material(s)
- Code 74178, Computed tomography, abdomen and pelvis; without contrast material in one or both body regions, followed by contrast material(s) and further sections in one or both body regions
CMS assigned those new CPT codes to existing APCs with payment rates that many felt were far too low to cover the costs of providing combined (two services).
Many organizations have been working hard to convince CMS that these new codes are just that, new codes but not new services. They argued that CMS should use its historical claims data to set appropriate payment rates for the single and combined CT services, Shah says.