Tuesday, November 1, 2022

CMS Final Rules for CY2022: OPPS and PFS

 After work hours on November 1, 2022, CMS released the Outpatient (OPPS) and Physician (PFS) final rules.

Home page for upcoming CMS documents at Fed Reg:

https://www.federalregister.gov/agencies/centers-for-medicare-medicaid-services

Find the OPPS final rule (inspection copy) here (1764pp):

https://www.cms.gov/files/document/cy2023-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center-final-rule.pdf

Find the PFS final rule (inspection copy) here (3304pp):

https://www.cms.gov/files/document/cy2023-physician-fee-schedule-final-rule-cms-1770f.pdf

Find association materials:

PFS Press Release here.

PFS Fact Sheet on shared savings here and on general topics here.

OPPS Press Release here.

OPPS Fact Sheet here.


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Final OPPS to appear here 11-23:

https://www.federalregister.gov/public-inspection/2022-23918/medicare-program-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center-payment

Final PFS to appear here 11-18:

https://www.federalregister.gov/public-inspection/2022-23873/medicare-and-medicaid-programs-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other



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I haven't digested these mountains of rulemaking, but one interesting bit.  In the OPPS system, CMS usually packages or bundles any services represented as an add-on code.  For Software as a Service, CMS will be able to pay add-on codes that are SaaS.  CMS states they will continually review and evolve policy in the software area.


In PFS rulemaking, CMS determines newly this fall that a stool cancer test (FIT or Cologuard) is part of a continuous process with a follow-up colonoscopy, so that, the colonoscopy does not require a copay when triggered by a stool test.  However, CMS declined, at this time, to extend the same logic to LBX tests as the first test.   This makes no sense to me; their own logic applies equally to stool or LBX tests.  To be continued, I’m sure