In this episode, we’re pleased to welcome BESLER’s Senior Reimbursement Consultant Tim Powell, to provide a sample of the information that he will be sharing in the upcoming 2023 OPPS Final Rule Summary webinar.Learn how to listen to The Hospital Finance Podcast® on your mobile device.
Highlights of this episode include:
- OPPS Final Rule Updates
- Sole Community Hospitals
- Organ acquisition
- New type of provider
- 340B program
Kelly Wisness: Hi, this is Kelly Wisness. Welcome back to the award-winning Hospital Finance Podcast. We’re pleased to welcome Tim Powell, senior reimbursement consultant on BESLER’s reimbursement team. Tim joined the BESLER team earlier this year and has extensive reimbursement experience. In this episode, Tim will give us a little sample of the information that he and a colleague will be sharing in the upcoming 2023 OPPS Final Rule Summary webinar they are hosting on December 14th, 2022, at 1:00 PM Eastern Time. Thank you for joining us today, Tim.
Tim Powell: Thank you, Kelly. It’s very nice to be on the program, and I appreciate being on the show.
Kelly: Well, great. Let’s get to it today. In the 2023 Outpatient Perspective Payment System, or OPPS Final Rule, did CMS make any updates to the hospital’s payment rate?
Tim: Yes, Kelly. CMS actually increased the OPDS conversion factor for current year 2023 by 3.8% from $84.18 to $85.59 for hospitals that meet the Hospital Outpatient Quality Reporting Program requirements. This increase is based on the hospital market basket percentage increase of 4.1%, reduced by a productivity adjustment of 0.3 percentage points. The 85.59 conversion factor is also net a budget neutrality adjustments for the 340B pro-payment update, wage index methodology, and a couple other changes in new and updated reimbursement provisions.
Kelly: Thank you for that. And we’ve had some clamor of a major change in clinic reimbursement for Sole Community Hospitals. Could you briefly touch on this for us?
Tim: Sure, Kelly. In order to maintain access to healthcare in rural areas, CMS reinstated full OPDS reimbursement for rural Sole Community Hospitals at accepted off-campus hospital-based outpatient departments, also known as provider-based clinics. This can be a huge benefit for rural SCHs that have multiple off-campus clinics. It’s about a 60% increase in reimbursement for these accepted clinics over the Medicare physician fee schedule amounts they’re receiving currently. In addition, CMS affirmed the additional 7.1% add-on for rural SCHs for OPPS services.
Kelly: Thank you for that great update. And is there anything new in organ acquisition in the OPPS Final Rule?
Tim: Yes, Kelly. CMS included a new method of accounting for research organs. This new methodology is implemented to improve payment accuracy and maintain organ availability for the research community. In the proposed rule, CMS issued a request for information for alternative methods for accounting Medicare transplanted organs to more accurately calculate Medicare’s share of organ acquisition at transplant hospitals and organ procurement organizations, or OPOs. CMS did not directly address any responses or finalize any policies in the Final Rule but stated that they will consider all comments and information submitted in future rulemaking.
Kelly: And Tim, in the 2023 OPPS Final Rule, did CMS create a new type of provider?
Tim: Yes, Kelly. CMS created a type of provider called a Rural Emergency Hospital, or REH. Effective January 1st of 2023. Critical access hospitals and rural hospitals with less than 50 beds can become Rural Emergency Hospitals. These hospitals will receive the base payment of OPPS plus 5% over the standard OPPS amount, plus a facility fee of a little over $278,000 per month. In addition, they’ll be able to bill for laboratory and fee screen payments that are normally paid to outpatient facilities. The deductibles billed to the patients is not going to include the 5% increase. And facilities wishing to change over to a Rural Emergency Hospital can simply change form 855A with a change of information in their PICO system without requesting a new provider number. They must have permissions available on-site or within 60 minutes, depending on the location, and the average length of stay can’t exceed 24 hours. And they also must have a prevention and antibiotic stewardship program.
Kelly: That all sounds like all great things. Did CMS reverse its position on cuts to the 340B program?
Tim: CMS has reversed its cuts to the separately payable drugs in the 340B program. But currently, this is only true for payments made after September 28th of 2022. For current year 2023, in light of the Supreme Court’s decision in the American Hospital Association versus Becerra, CMS is finalizing a general payment rate of ASP plus 6% for drugs and biologicals acquired through the 340B program. Consistent with our policy or drugs not acquired through the 340B program, and as required by statute, CMS is implementing a 3.9% reduction in payment rates for nondrug services to achieve budget neutrality for the 340B drug program rate change for current year 2023. CMS will address the remedy for the 340B drug payments from 2018 through 2022 and future rulemaking. And prior to this, current year 2024 OPPS ASC proposed rule. And they note that the claims for the 340B acquired drugs paid after the District Court’s decision on September 28th of the ruling are going to be paid at the default rate, which is generally ASP plus 6%.
Kelly: Fantastic. And thank you so much for joining us today, Tim, and for these great insights.
Tim: Thank you very much. I really appreciate the opportunity to speak, and we look forward to sharing more on our actual webinar. Thank you, Kelly.
Kelly: Yeah. So, we appreciate you giving us that glimpse into what you plan to share in the upcoming webinar on December 14th at 1:00 PM Eastern Time. And as a bonus, you can earn CPE. And thank you all for joining us for this episode of The Hospital Finance Podcast. Until next time…
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