On September 17, the AACU submitted a formal comment letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed CY 2022 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System rule. In addition to the standard annual updates, the rule proposes to reverse two policies related to the inpatient only (IPO) list and the ASC covered procedures list (CPL), both of which the AACU opposed in its letter.
CMS proposes through this rule to reverse a previous decision to move hundreds of inpatient services to the outpatient setting. This reversal would add back 298 services to the IPO list and remove 258 services that were added to the CPL. Reinstating the IPO list shifts decision making regarding the most appropriate setting for certain procedures away from physicians and patients and back into the hands of payers.
The AACU also opposed the decision to remove 258 services, including several urologic procedures, from the ASC CPL as many of these procedures are most suited to be performed on an outpatient basis. The AACU letter identified several advantages to performing certain urological procedures in an ASC vs. a hospital setting, such as more personalized care, greater efficiency, higher patient satisfaction and reduced costs.
Finally, the AACU advocated for CMS to update its valuation for Extracorporeal Shock Wave Lithotripsy (ESWL) and High Intensity Focused Ultrasound (HIFU) when performed in an ASC setting. The current payment rate for ESWL does not accurately reflect the high equipment acquisition costs for performing the procedure, while the APC code assigned to HIFU as of 2019 reduced hospital reimbursement for the procedure to half of the previous level. AACU’s letter urged CMS to reassign HIFU to a Level 6 APC, which is “clinically appropriate and economically necessary to facilitate access to this technology for Medicare beneficiaries with localized prostate cancer”.