Bundling at ASCs

[pathstudent]

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I do pathology for a number of surgery centers that are operated by a huge corporation. Their executives are saying that bundling of pathology services doesn't apply to free standing ASCs and they pointed out a part of the document which "proved" it.

I am not sure CAP or my billing company or pathologyblawg know what they are talking about as I would go with the compliance lawyers at the corporation.

 

[Crossed Path]

Not surprising that the corporate execs would interpret it that way, but I suspect they're wrong. Yes, the 2015 CMS rules do not explicitly state that pathology TC codes will be bundled with ASC payments. But, they do say that the policy provides packaged ASC payment for ancillary items and services that are packaged or conditionally packaged under the OPPS. The bundled codes in the OPPS include the TC component for 88305, 88307, 88312, etc. In other words, if A=B and B=C, then A=C. The rules do not state whether this applies only to ASCs with in-house histology or if includes those that use an outside, contracted lab. I strongly suspect CMS won't care about the difference and will lump them all together.

Corporate compliance lawyers can interpret it however they want, but CMS gonna do what CMS gonna do. Winter is coming.

 

[pathstudent]

Not surprising that the corporate execs would interpret it that way, but I suspect they're wrong. Yes, the 2015 CMS rules do not explicitly state that pathology TC codes will be bundled with ASC payments. But, they do say that the policy provides packaged ASC payment for ancillary items and services that are packaged or conditionally packaged under the OPPS. The bundled codes in the OPPS include the TC component for 88305, 88307, 88312, etc. In other words, if A=B and B=C, then A=C. The rules do not state whether this applies only to ASCs with in-house histology or if includes those that use an outside, contracted lab. I strongly suspect CMS won't care about the difference and will lump them all together.

Corporate compliance lawyers can interpret it however they want, but CMS gonna do what CMS gonna do. Winter is coming.

Winter may be coming but it is not here yet. I disagree. This corporation is too big to risk the ire of CMS. Moreover common sense says this can't apply. It would be too drastic with too short of notice.

When I called the individual directors for the ASCs, none of them had heard about it. They contacted their boss who contacted his boss at the corporate HQ who contacted the person at CMS involved in writing it and clarified that it doesn't apply to non hospital ASCs.

This is the key passage.

Unlike the OPPS claims processing system that can be configured to make a single payment for the encounter based comprehensive service whenever a HCPCS code that is assigned to a comprehensive APC appears on the claim, the ASC claims processing system does not allow for this type of conditional packaging. Therefore, we proposed that all separately paid covered ancillary services that are provided integral to covered surgical procedures that would map to comprehensive APCs would continue to be separately paid under the ASC payment system instead of being packaged into the payment for the comprehensive APC as under the OPPS.

 

[caffeinegirl]

check this out...looks like we are in the clear (not on the pathologyblawg mainpage just yet)
http://pathologyblawg.com/pathology...ail&utm_term=0_d76ed06817-574407c347-63785169

 

[Crossed Path]

Definitely more tolerable if the bundling only applies to hospital-run surgery centers, but I think it's still unclear. Is the passage you quote in the CMS rules or from a personal communication?

 

[Crossed Path]

check this out...looks like we are in the clear (not on the pathologyblawg mainpage just yet)
http://pathologyblawg.com/pathology-news/regulatoryoversight/cms/important-update-regarding-cms-2015-ancillary-services-packaging-policy/?utm_source=Pathology Blawg&utm_campaign=574407c347-RSS_EMAIL_CAMPAIGN&utm_medium=email&utm_term=0_d76ed06817-574407c347-63785169

Woo hoo!

 

[BamaAlum]

I would say that if Jane Pine Wood went on record that she spoke with CMS and the new rule does NOT apply to freestanding surgery centers, then I would believe her. She has carved out quite a niche in the specifics of healthcare law as they relate to the laboratory industry.

 

[caffeinegirl]

Anybody heard from CAP or other organizations regarding this??

Would like to hear from an "official" entity before closing the book on this one...

 

[pathstudent]

Anybody heard from CAP or other organizations regarding this??

Would like to hear from an "official" entity before closing the book on this one...

Who cares what cap says. They and the blawg are thebones that started this misinformation and got us in a panic. Eventhough common sense said it wouldn't go down like this.

I'm going with the compliance lawyers from the billion dollar corporation that runs the ascs I do business with. They told me it doesn't apply and forwarded me communication they had with one of the writers of the policy and they said don't worry about it.

 

[caffeinegirl]

Who cares what cap says. They and the blawg are thebones that started this misinformation and got us in a panic. Eventhough common sense said it wouldn't go down like this.

I'm going with the compliance lawyers from the billion dollar corporation that runs the ascs I do business with. They told me it doesn't apply and forwarded me communication they had with one of the writers of the policy and they said don't worry about it.

Thanks pathstudent for the followup. I am quite disillusioned that none of the actual pathology organizations out there would address this. Oh well...

 

[LADoc00]

This is bad for me, I had this grand plan to drive tons of ASC business to me using fear tactics.