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OOSS AND AAO ISSUE ANSWERS TO YOUR QUESTIONS ABOUT THE NEW MEDICARE CONDITIONS FOR COVERAGE
Michael A. Romansky, JD Senior Counsel, OOSS
What are the CFCs governing œpatient rights?
Generally speaking, when, and in what form, is the ASC required to notify the patient of his rights?
When should informed consent be obtained vis-Ã -vis the myriad of other advance notice requirements?
When should information about the ASC™s Advanced Directives policies be provided to the patient?
When does this regulation take effect? What if our policies and procedures have not yet been fully updated to reflect the changes in the new Conditions for Coverage? (more…)
OOSS AND AAO ISSUE ANSWERS TO YOUR QUESTIONS ABOUT THE NEW MEDICARE CONDITIONS FOR COVERAGE
Michael A. Romansky, JD Senior Counsel, OOSS
Last week, you received from OOSS a Primer and Frequently Asked Questions regarding the Medicare ASC Conditions for Coverage (CfC) that became effective on May 18. We are reissuing this presentation so that you can access it through either Washington Update Online or Ask Mike! Because of the length of the document, we have also reformatted the FAQ so that you can scroll below to a specific question and click immediately to the answer.
Should you have further questions, please feel free to contact me at mromansky@OOSS.org as the FAQ will be periodically updated to be responsive to your concerns. (more…)
Question and Answer
Legislating Higher ASC Facility Fees
Q: Under the new payment system, ASC facility fees don™t seem to have risen at the pace we expected. Why is this? Does OOSS have plans to address the problem?
Answer:
We are disappointed with CMS™ efforts with respect to the implementation of the ASC payment system that was launched in January, 2008. The good news is that the agency adopted our recommendations to expand the ASC procedures list to include virtually every ophthalmic surgical procedure and to link ASC payment rates to the reimbursement afforded hospital outpatient departments (HOPD). The bad news is that the methodological linkage is imperfect; our payment rates represent only 59% of the amounts paid to HOPDs and, without change in the regulations, the ratio could decline to 52% by 2013. Why is this occurring? CMS is required to keep the new payment system budget neutral; the mechanism the agency is using to achieve neutrality “ known as œsecondary rescaling “ is arbitrary and irrational and is driving down rates. The gap between HOPD and ASC rates is also widening because CMS will provide ASCs, commencing in 2010, with an annual update based on the Consumer Price Index “ Urban (CPI-U), while HOPDs receive an increase based on the Hospital Market Basket index, which is typically about a point higher. (It is important to note that even under the current system, while the percentages are declining, the actual payment rates for most ophthalmic surgical procedures will increase over the next five years, e.g., cataract by 5%, detached retina repair and glaucoma surgery by 27%). (more…)
Ask MIKE!
Michael A. Romansky, JD, OOSS Washington Counsel
Ask Mike! examines and answers some of the more popular ophthalmic ASC questions. Everything from practice management, to legal, finance, coding, certification, and legislative commentary. Plus, we’ll point you toward the resources we recommend for further information. (more…)
Ask MIKE! “Can an ASC Flash Sterilize or Not?”
Hey Mike, can an ASC Flash Sterilize or Not?
Mike’s answer: I’ve heard that, recently, Medicare has ruled that ASCs that use flash sterilization are out of compliance with Medicare conditions of coverage and my lose their certification. Is this true? Don’t most ophthalmic ASCs use flash sterilization? (more…)
ASK MIKE!
Michael A. Romansky, JD, OOSS Washington Counsel
Below are a few of the important and intriguing questions that have been proffered by your colleagues of late.
Facility Payments for Office Surgery It appears that a lot of new codes are going to be added to the ASC procedures list, including 65855 (laser surgery). Right now, we bill for the professional fee. Starting January 1, if we perform the service in the ASC, we can bill for the ASC facility fee. I suspect that this will result in a lower professional fee that offsets the gain. Should I move my laser into the ASC? (more…)
ASK MIKE!
Michael A. Romansky, JD, OOSS Washington Counsel
Below are a few of the important and intriguing questions that have been proffered by your colleagues of late.
Facility Payments for Office Surgery It appears that a lot of new codes are going to be added to the ASC procedures list, including 65855 (laser surgery). Right now, we bill for the professional fee. Starting January 1, if we perform the service in the ASC, we can bill for the ASC facility fee. I suspect that this will result in a lower professional fee that offsets the gain. Should I move my laser into the ASC? (more…)
ASK MIKE!
Michael A. Romansky, JD, OOSS Washington Counsel
After working on this OOSS priority for so many years, what do you really think of the new ASC payment rule in 25 words or less? (more…)
ASK MIKE!
The Trusted Source for Answering your Ophthalmic Facility ASC Questions
Don’t take me literally, but how often do you get to take a free shot at a lawyer? You now have an ongoing opportunity to throw your questions my way, and I’ll do my best to give you the right answers, or at least point you in the right direction. Whatever your concerns may be coding, reimbursement policy, the new ASC legislation or payment regulation, a prospective joint venture, comanagement, certificate-of-need or Medicare certification, just to name a few send them my way. Hopefully, your query will be of interest to the general membership and the Q & A will be made available to all of your colleagues on the OOSS website in the Ask Mike column. My friends: let’s keep the cards and letters coming, although it is best to reach me at AskMike@OOSS.org. (more…)
