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CY 2016 OPPS Final Rule-Post Implementation Challenges

Another January 1 has come and gone, and we continue to address the challenges in our revenue cycle operations resulting from the implementation of the CY 2016 OPPS Final Rule. One of those changes is that the L1 modifier will be used to report only the lab tests that are performed on the same day as other services but for a different reason (and ordered by a different physician) while stand-alone lab tests will no longer require the L1 modifier. Are you still struggling to find a way to report this modifier correctly? Another change is in the billing and coding of services concerning stereotactic radiosurgery: CMS is pulling the costs for planning and preparation services related to SRS treatment delivery (CPT® codes 77371-77372) and will pay planning and preparation services according to their assigned status indicator when furnished 30 days prior to or 30 days post SRS treatment delivery. Our challenge with this change is the implementation of the new modifier: “CP” (Adjunctive service related to a procedure assigned to a comprehensive ambulatory payment classification [C-APC] procedure). CMS clarified how to use this modifier during this week’s CMS Hospital Open Door Forum. They said the modifier is NOT needed on the CPT codes for planning and preparation but is required for ALL OTHER adjunct services furnished 30 days before and 30 days after the date of the SRS delivery. Another challenge: In late December, CMS released new HCPCS codes (G-codes) for lab tests used for drug testing. During this week’s Hospital ODF, CMS stated that the policy took longer than intended; therefore, the codes were not finalized in time for the January 2016 OPPS CR that includes all payment rates. CMS has instructed the MACS to HOLD claims containing the new G-codes until the April 2016 update can be implemented. Lastly, CMS also discussed the “PO” modifier which became mandatory for January 1, 2016. They have received many questions regarding the upcoming changes to off-campus provider based departments for which they have posted an FAQ document. Anyone who’s worked in revenue cycle has by now gotten used to these sorts of challenges. How do you and your team prepare and address each year’s changes?  Have you run across other post-implementation challenges resulting from the CY 2016 OPPS Final Rule? We’d love to hear from you!
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