From the November 2016 issue of HealthCare Business News magazine
Hospitals are still contemplating how to fix the problems in the original site-neutral legislation regarding the grandfathering of facilities under construction, to be paid under the hospital outpatient department fee schedule, versus the physician fee schedule. CMS has a very narrow interpretation regarding hospital services and facilities, including when the grandfather clause will be effective and when it won’t. In addition, CMS proposes that hospitals would have to find a way to re-register under the Medicare program as a physician office to continue to be paid in 2017 for their non-grandfathered outpatient services.
How the comments on the proposed rule are taken into consideration, and changes made in the final rule, could determine if the hospital community unifies around a position and goes to Congress for help in the lame duck. There is already legislation introduced to stop the Medicare Part B Drug Demonstration Program. Depending on how CMS adapts and changes that program based on comments regarding the proposed rule when it releases the final version, Congress could decide it needs to act. This would then provide a highly-motivated opportunity for other health care legislation to be added on.
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Where does imaging fit into all of this and where should there be concern? First is the impact that the finalization of the site-neutral policies and the grandfathering of the outpatient facilities will have. How CMS makes changes could determine the ability of hospitals to expand imaging services. Second, whenever there is Medicare-related legislation that may cost money to enact, like the repeal of the Medicare Part B Drug Demonstration Project, imaging is often on the reimbursement reduction list to pay for some of the cost. This is something that the imaging community must guard against.
About the author: Jill Rathbun is managing partner at Galileo Consulting Group.Back to HCB News
