AGA Voices Concerns to CMS Re: 2011 HOPD & ASC Proposed Rule

September 02, 2010

On Aug. 31, AGA, along with ASGE and ACG, provided comments to CMS on the proposed policy revisions to hospital outpatient departments (HOPDs) and ambulatory surgical centers (ASCs) for 2011. (The proposed rule was published in the Aug. 3 Federal Register.)

There are a number of provisions in the proposed rule that impact practicing gastroenterologists and the Medicare beneficiaries they treat. Our comments focused on the following issues:

  • Upper GI current procedural terminology code reassignment within the ambulatory payment classification (APC) system (APC 0141/0422).
  • Reassignment of 43240 (upper gastrointestinal endoscopy, including esophagus, stomach, and either the duodenum and/or jejunum, as appropriate; with transmural drainage of pseudocyst from APC 0141 to APC 0384, GI procedures with stent).
  • Wage index.
  • Secondary rescaling of APC relative weights for ASCs.
  • ASC conversion factor and productivity adjustment.
  • Extension of waiver of deductible to services furnished in connection with or in relation to a colorectal cancer screening test that becomes diagnostic or therapeutic.
  • Cost reporting.
  • Reporting ASC quality data.

CMS will publish its final rule affecting HOPDs and ASCs by Nov. 1.