LUGPA Policy Update - LUGPA Comments on CY 2025 Medicare OPPS and ASC Payment System Proposed Rule

Sept. 2024 

On August 26 2024, LUGPA formally submitted comments on the CY 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule [CMS-1809-P], expressing strong support for several key provisions while advocating for further considerations in specific areas.

Our recommendations focus on ensuring the continued stability of payment systems, promoting site neutrality, reducing reporting burdens, and facilitating access to cutting-edge urological technologies.

Key Recommendations

1. Reassignment of CPT Code 0655T: LUGPA supports CMS’s proposal to reassign CPT code 0655T from APC 5374 (Level 4 Urology and Related Services) to APC 5375 (Level 5 Urology and Related Services). This reassignment aligns CPT code 0655T with other procedures of similar resource cost and clinical homogeneity, such as CPT codes 0714T and 52648. However, LUGPA urges CMS to closely monitor the impact on APC 5375 and revisit this issue in future rulemaking cycles to maintain payment stability for APC 5375.

2. Continuation of PFS-Equivalent Rate for Outpatient Visits: LUGPA endorses CMS’s proposal to continue applying a Physician Fee Schedule (PFS)-equivalent payment rate for hospital outpatient clinic visits when provided by non-excepted off-campus provider-based departments (PBDs). This policy advances CMS’s broader site-neutral payment objectives, promoting access to care in more cost-effective and convenient settings. While recognizing the unique role of rural Sole Community Hospitals (SCHs), LUGPA encourages CMS to further explore site neutrality in all settings, including emergency department (ED) visits, with appropriate safeguards to ensure patient access is not compromised.

3. Adoption of Invoice Pricing for OPPS-Payable Drugs Without Pricing Information: LUGPA supports the adoption of an invoice pricing policy for drugs administered in the hospital outpatient and ASC settings that lack available pricing information. This approach would alleviate financial uncertainties for providers and enhance patient access to novel procedures and therapeutics. LUGPA emphasizes that this policy is essential for maintaining the availability of innovative treatments in the outpatient setting.

4. Reducing Reporting Burdens on ASCs: LUGPA supports CMS’s efforts to reduce the reporting burden on ASCs by ensuring that only the most meaningful reporting measures apply to each facility. The proposed case threshold minimum for non-claims-based specialty-specific measures will help tailor reporting requirements to the services most relevant to each ASC. Additionally, LUGPA advocates for the exclusion of Medicare Advantage (MA) claim volume when determining case volume thresholds, as this could lead to an inaccurate representation of an ASC’s primary services.

5. Increasing ASC Payment Rates Using the Hospital Market Basket Methodology: LUGPA strongly supports the continued use of the hospital market basket methodology to update ASC payment rates. This approach ensures that ASC payments reflect the true cost trends in the hospital sector, helping to sustain the financial viability of ASCs and preserve access to high-quality, cost-effective surgical services.

6. Ensuring Equitable Access to Urological Technological Advancements: LUGPA reiterates its commitment to ensuring that all patients have access to the latest advancements in urological care. We urge CMS to adopt and maintain policies that promote the integration of cutting-edge diagnostic tools, minimally invasive surgical techniques, and novel therapeutic devices into urology practices. Reimbursement frameworks should be designed to facilitate the adoption of these technologies, ensuring that patients across all socioeconomic backgrounds can benefit from the best available care.

LUGPA remains dedicated to advocating for policies that support the delivery of high-quality, cost-effective urological care in independent practice settings. We look forward to continuing our collaboration with CMS to advance these goals and improve patient outcomes in the urological field.

You can find the full letter here: https://lugpa.memberclicks.net/assets/docs/2024/LUGPA%20CY%202025%20OPPS_ASC%20Proposed%20Rule%20Comment%20Letter%20%2808-26-2024%29.pdf.