From the May 2015 issue of HealthCare Business News magazine
It is hard to tell what office-based payments for imaging services would have been in 2015 if they had been left untouched as many other services in the physician fee schedule have been. Would there have even been a site of service difference in payments between hospital outpatient departments and physician offices?
Another element that MedPAC states is necessary to put the site-neutral payments principle in place is the similar characteristics regarding the Medicare beneficiary that is being treated.
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Emergency rooms at trauma centers, for the purposes of billing Medicare, are considered hospital outpatient departments, unless the patient is admitted to the hospital as an inpatient and then the cost of all the services provided in the ER get rolled into the DRG payment for the admission.
In many instances, patients getting care and who are in need of diagnostic imaging services in an emergency room or trauma center could have a higher level of acuity than a patient that is seen in physician offices for a previously scheduled diagnostic imaging study.
Even MedPAC, in constructing the list of services that would be compared, had an elimination criterion for services in which the volume performed in an emergency room department was too high to make it comparable to services provided in a physician office. There would also need to be considerations for facilities in rural areas and for facilities which, due to financial instabilities, had no other choice but to form some type of alliance to be able to keep the doors open to provide for access to care in their community.
While, on their face, comparing payments between various sites of services looks to be a relatively easy apple-to-apple comparison, it is much more complicated and possibly even impossible due to all the nuances of the various systems. And it could be distracting at a time where everyone is trying to develop alternative payment models that are more about performance and value than unit prices.
About the author: Jill Rathbun is managing partner at Galileo Consulting Group, in Arlington, VA. She will be commenting for DOTmed Health- Care Business News magazine on such vital issues for all health care professionals as the implications of the President’s FY 2016 budget, the new makeup of Congress, possible Medicare payment proposals from the Centers for Medicare and Medicaid Services, reports from the Medicare Payment Advisory and more.
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