The 2022 Hospital Outpatient Prospective Payment System and ASC Payment System proposed by CMS is filled with changes that are more curious than cause for serious concern. CMS, which ultimately intends to slow the migration of surgeries from hospitals to ASCs, wants to make two major changes to facility reimbursements next year:
• Do away with the plan to eliminate the inpatient-only list (IPO) by 2024. Nearly 300 of the 1,700 procedures were removed on Jan. 1, 2021. CMS wants to put them back on the list next year.
• Remove 258 of the 266 procedures that were added to the ASC-approved list this year.
Importantly, knee and hip replacements remain on the ASC-approved list. The cardiovascular codes added to the list in recent years — including those for diagnostic and interventional procedures — will also remain.
“We received a large number of stakeholder comments … that opposed the elimination of the IPO list primarily due to patient safety concerns, stating that the list serves as an important programmatic safeguard,” says CMS in a statement explaining its proposal.
The agency notes that some of the procedures on the IPO list include amputations and invasive spinal procedures. “There are some services designated as inpatient-only that, given their clinical intensity, would not be expected to be performed in the outpatient setting,” says the agency. “This change happened without individually evaluating whether the procedures met the longstanding criteria previously used to determine if a procedure could be safely removed.”
Regarding the ASC-approved list, CMS again cited patient safety concerns as the reason for its proposed reversal. The agency wants to adopt a process by which individual procedures could be nominated and considered for addition to the list.