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CMS Releases OPPS Final Rule for 2011

Michelle A. Leppert, CPC-A, for HealthLeaders Media, November 4, 2010

Reporting ancillary services with critical care

Another significant change comes as a result of a change by the CPT Editorial Panel, which is revising its guidance for critical care codes 99291 and 99292 to specifically state that, for hospital reporting purposes, critical care codes do not include the specified ancillary services.

This means beginning in CY 2011, hospitals can and should report in accordance with the CPT guidelines that will allow the separate reporting of ancillary services and associated charges when provided in conjunction with critical care. These ancillary services include, but are not limited, to electrocardiograms, chest X-rays, and pulse oximetry.

The immediate good news, Shah says, is that beginning in 2011 hospitals are going to be able to report the ancillary services they provide in conjunction with critical care. The bad news is that hospitals will not receive APC payment for those services because CMS said it has already factored those costs into the development of the critical care APC payment rate from historical claims data where the cost of these services was included in the critical care charge.

"This is another win for the hospital community because they have been trying individually through comment letters and through the American Hospital Association to get CMS and/or the AMA through the CPT Editorial Panel to realize that hospitals should be allowed to report and obtain payment for these ancillary services in addition to the reporting and payment for critical care," Shah says.

CMS is requesting comments on this issue so hospitals should provide feedback on how CMS should treat the revision of the CY 2011 critical care codes for the future, especially with respect to generating separate payment. The rule of course covers other changes, including:

  • An increase to the drug packaging threshold from $65 to $70
  • A slight increase in separately payable drug reimbursement from ASP + 4% today to ASP+5% in the future
  • Removal of three codes from the inpatient-only list
  • Co-insurance and deductibles for preventive services
  • Wound care coding and payment
  • The outpatient hospital quality initiative
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