CMS Prospective Rate Analysis Commentary August 2023

CCA Partners and Prospective Partners,

The 2024 CMS Proposed PFS and OBL Rates were released in July 2023. The rates will be finalized in the October for Jan 2024 implementation and are subject to change. The following are CCA’s key takeaways pertaining to the services lines supported in CCA’s facilities. Rates notes are national averages for simplicity and relatively vary by specific locality.

• CMS continues to demonstrate a preference for the ASC setting over the Office Based (OBL) setting for cardiovascular and endovascular procedures by generally increasing ASC fee reimbursements while cutting the OBL reimbursement. The ASC technical fees are in MOST cases greater than the combined OBL Global rates, which include both professional and technical components. Adding the professional fee to the analysis furthers the preference for the ASC.
• Peripheral Interventions are now paid in the ASC greater than the OBL and will drive a shift of PAD care from the OBL setting to the higher standards of the ASC setting.
  • Examples:
    • Femoral/Popliteal revascularization w/atherectomy (37225) is proposed at $12,397 in the ASC and $8,739 in the OBL. This is completely flipped from 2021 and in 2024 pays more in the ASC than 2021 OBL rates.
    • Iliac Revascularization w/Stent (37221 ) is proposed at $6,833 in the ASC and $2,962 in the OBL.
• Cardiac Catheterization and PCI receive significant uplifts in the ASC and decreases in the OBL furthering the argument of an overall CMS site of services strategy shift for endovascular procedures to the ASC.
  • Examples:
    • Left Heart Catheterization (93452) is proposed at $1,598 in the ASC and $869 in the OBL.
    • PCI w/DE Stent (C9600) is proposed at $6,741 in the ASC and not payable in the OBL
• Primary disappointment from the ASC perspective is CMS limited CPT additions to the ASC fee schedule. We are still pushing for the inclusion of Cardiac Ablations, Cardioversions, and other appropriate procedures.
  • CCA is currently working with multiple commercial carriers to cover these procedures and more
• CRM Device Rates largely stayed unchanged resulting in a real net decrease compared to inflation; however these rates remain competitive and reasonable for care in the ASC Setting. CRM devices are not paid in the OBL.
• Dialysis access received significant uplifts in the ASC proposal, solidifying ASCs as the preferred site of care
• CMS appears to be following the same ASC preference trend in IR. A significant example is arterial vascular embolization/ occlusion (37242) procedures receiving a 75% increase in the ASC to $11,762, compared to 7% decrease in the OBL to $6,788. This drastic change, if finalized, clearly indicates the CMS preferred site of service as the ASC for these procedures.

Tim Price, CEO CCA