With a proposed rule for the 2020 ASC payment system expected to be released in late June or early July, the Renal Physicians Association has sent recommendations to CMS aimed at stabilizing the payment structure for vascular access services for patients with ESRD by maintaining current endovascular ambulatory payment classifications.
In a letter to the agency on March 8, RPA President Michael Shapiro, MD, wrote that the association supported a decision by CMS in the 2019 final rule governing payment for ASCs to maintain the four-level structure for the endovascular procedures, “and we believe that CMS should continue this structure for 2020,” Shapiro wrote. “We believe that this structure strikes the right balance between groupings within the context of a prospective payment system and granularity that recognizes differential resource costs.
“We also believe that the current four-level structure supports clinical homogeneity regarding the relative complexity of the various procedures, many of which represent increasing complexity within a code series,” he said.
The RPA did recommend specific payment code reorganization, including the reassigning of 12 of the highest cost codes in the Ambulatory Payment Classification (APC) codes.
“These code reassignments would eliminate overlap among cost ranges for significant codes in consecutive APCs in the endovascular APC series, which would improve the resource homogeneity among the APCs in this series without any significant adverse effects on the payment rates for individual codes,” Shapiro wrote.