California Division of Workersâ€™ Compensation Proposing Changes to the ASC Fee Schedule
The California Division of Workers’ Compensation (DWC) is proposing to revise the hospital outpatient departments and ambulatory surgical centers fee schedule (HOPD/ASC fee schedule). The proposed changes call for the elimination of the alternative payment methodology.
According to the DWC, only one ASC in the state currently participates in the alternative payment methodology, often referred to as high cost outlier program. Most ASCs adopt to utilize the maximum allowable payment, which is based on a multiplier that includes an extra percentage reimbursement for high cost outlier cases, in lieu of additional payment for high cost outlier cases. Due to the lack of utilization by ASCs of the alternative payment methodology, and the fact that ASCs are not licensed and do not report cost data, the DWC is proposing to eliminate the alternative payment methodology.
Most disturbing is that the DWC is proposing to reduce the additional payment from the current 82% of the Hospital Outpatient Department Prospective Payment System (HOPD PPS) fee schedule, to a percentage amount currently proposed at 80.8 percent of the HOPD PPS fee schedule.
The CASA Board strongly opposes these proposed amendments. CASA Legislative Advocate, Bryce Docherty, testified at a DWC hearing March 11, 2014, regarding our tremendous concerns with this reduction. In addition, CASA submitted formal comments to the DWC. The CASA Comments and testimony focused on the following:
- Opposed to proposed amendments to Section 9789.30, Subdivision (aa), which eliminates the option for ambulatory surgical centers to use an alternative payment methodology and further decreasing these facility fees from a Medicare multiplier of 82 percent down to 80.1 percent.
- Request the DWC to adopt the same Hospital Outpatient PPS geographic-adjusted conversion factor utilized by Medicare.
- Propose ASC-specific fee schedule for those procedures codes not listed as part of the Medicare HOPD payment methodology.
The DWC has yet to approve an updated fee schedule for 2014. ASCs should continue to utilize the 2013 fee schedule until the DWC formally adopts a schedule for 2014. Please utilize the links below for further information.
California ASC Input Needed on Proposed Emergency Preparedness Requirements
The Centers for Medicare & Medicaid Services (CMS) recently proposed expanding current emergency preparedness requirements in an attempt to align standards across all health care providers. CASA, in coordination with ASCA, believes many of the proposals contained in the proposed rule that would apply to ASCs, are inappropriate for our setting and would be burdensome to implement. ASCs in California often have difficulty with their local counties and Emergency Management Systems willingness to include ASCs in their plans as proposed by CMS. CASA submitted a letter in coordination with ASCA, addressing industry concerns. It is critical that California ASCs become involved and contact CMS.
To deliver the most impact, California ASCs should provide specific details regarding how the proposal impacts your center and why it should be reconsidered. Provided below are talking points to assist you with drafting your letter. You may submit your letter electronically to CMS at the following link. Click here to comment on the proposed changes. Comments are due March 31, 2014.