More than 750 procedures that were once excluded from ASCs are permitted under CMS' payment plan for 2008, but many of these approved CPT codes represent very minor surgical procedures. What's more, around 350 of them will be reimbursed at a reduced ASC rate because CMS wants to prevent inappropriate migration of these services from office suites to ASCs.

The added procedures cover nearly every specialty. They fall into two general categories:

• Those with payment caps. This indicates that they're minor procedures that are performed in physician offices most of the time. The payment cap is a disincentive for ASCs to heavily recruit these procedures into their facilities, although ASCs may find that booking them into suites during slow times may help mitigate operational costs.
• Those without payment caps. This indicates that, until now, these procedures were performed in inpatient facilities. CMS has determined that these procedures, though complex and somewhat risky, still fall within the realm of safety for ASCs. This second group is the group of procedures that you'll likely want to actively recruit into your operating suites.

See anything you like?
Here's a look at a few interesting additions, including notes about their payment limitations:

• Integumentary procedures, including incision and drainage, foreign body removal and debridement, are greatly expanded. These procedures have payment capped at Medical Physician Fee Schedule (MPFS) rates and are designated as office-based, so the ASC payment is subject to a reduction for non-facility practice expense from the MPFS.
• Application of casts and strapping, subject to a reduction for non-facility practice expenses.
• Dozens of fracture and dislocation reduction procedures, with a mix of status for non-facility practice expense reductions.
• Injections or aspirations in joints or bursa, including trigger points, tendons, ligaments and cysts. These are also subject to MPFS reductions.
• Procedures not subject to office-based limitations include percutaneous vertebroplasty or kyphoplasty (thoracic or lumbar); artery or vein repairs; high-energy extracorporeal shock wave therapy for plantar fasciitis; lung procedures, including treatment of collapsed lung, insertion of pleural catheter or tube thoracostomy; renal endoscopies, laparoscopic cholecystectomy and endocervical procedures including LEEP, curettage, cauterization, cryocautery or biopsy; and treatment of endoscopic pregnancy and laparoscopically assisted vaginal hysterectomy.
• Transplant therapy procedures vary in their payment limitation rules. This procedure category includes stem cell or bone marrow or lymphocyte harvest or transplant; biopsy; apheresis of platelets, plasma white or red cells; and photopheresis.
• Oral and maxillofacial surgery procedures, varying from lesion removal from inside the mouth to reductions and reconstructions of facial bones. These procedures vary in their payment limitation rules.

Digging deep for details
Medicare excludes from ASC payment procedures that pose significant operative risk to patients or that require inpatient stays at the hospital. Multiple procedures continue to be reimbursed at rates of 100 percent for the primary procedure and 50 percent for each additional procedure under the new plan. For more than 150 procedures, no multiple surgical reduction will be taken. Typically, this is because the cost of the device associated with this procedure is a high portion of the reimbursement.

ASCs are paid a reduced amount for some procedures when they receive a partial credit for more than 50 percent of the cost of a medical device. ASCs must include modifier FC on these procedure codes, to identify partial credit for more than 50 percent of the cost of the device.

The new ASC rules are complex enough to warrant a focus on training and education, especially because the Office of Inspector General has added ASC payments in its 2008 work plan.

Physicians will also find their ASC place-of-service coding under scrutiny in 2008 because errors in place of service were seen to be a significant problem in 2007. Typically, physicians mistakenly report a place-of-service code for the office (11) rather than the ASC (24).

Choose your spots
In addition to understanding the nuances of the changes to approved procedures and payment amounts, understand how your carrier is reacting to the changes, and monitor your payments to ensure reimbursements are appropriate. Expect some hiccups in the system as everyone adjusts, and watch for the next round of regulatory changes headed our way.