Several of you have requested a recap of the recent CMS article on the CY 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS 1809-P).
Key Takeaways from the CY 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (CMS 1809-P):
Payment Rate Updates:
CMS proposes updating OPPS and ASC payment rates by 2.6% for hospitals and ASCs that meet applicable quality reporting requirements. This update is based on a projected hospital market basket increase of 3.0%, reduced by a 0.4 percentage point productivity adjustment (CMS.gov, eCQI Resource Center).
Intensive Outpatient Program (IOP):
The proposed rule updates Medicare payment rates for IOP services provided in hospital outpatient departments and Community Mental Health Centers (CMHCs). The existing rate structure, with different rates for three services per day and four or more services per day, will be maintained (CMS.gov, eCQI Resource Center).
Partial Hospitalization Program (PHP):
Similar to IOP, the rule proposes maintaining the current rate structure for PHP services, with two separate APCs based on the number of services provided per day. Payment rates will be based on CY 2023 claims data and the latest available cost information (CMS.gov, eCQI Resource Center).
Access to Non-Opioid Treatments for Pain Relief:
CMS proposes implementing additional payments for certain non-opioid pain treatments in hospital outpatient and ASC settings from January 1, 2025, through December 31, 2027. This initiative is part of the effort to expand access to non-opioid alternatives for pain management (CMS.gov, eCQI Resource Center).
Behavioral Health and Health Equity:
The proposed rule includes measures to address health disparities and expand access to behavioral health care. This aligns with the administration’s goals of promoting safe, effective, and patient-centered care, informed by lessons learned from the COVID-19 pandemic (CMS.gov, eCQI Resource Center).
Refinement of Definitions and Policies:
CMS is proposing to narrow the definition of "custody" to facilitate Medicare access for individuals on parole, probation, or home detention. This change aims to remove barriers to healthcare access for recently released individuals and those under supervision (CMS.gov).
Comment Period and Final Rule:
The proposed rule was published on July 10, 2024, with a 60-day comment period ending on September 9, 2024. The final rule is expected to be issued in early November (CMS.gov, eCQI Resource Center).
These proposed changes reflect CMS’s ongoing efforts to update and refine Medicare payment systems, ensuring they remain equitable and effective in delivering healthcare services. Healthcare providers should prepare for these updates and consider the potential impacts on their operations and reimbursement strategies.
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