AARC Meets with CMS over Reduced Payment for Pulmonary Rehabilitation
August 30, 2011
Representatives from AARC, the American Association for Cardiovascular and Pulmonary Rehabilitation, the American College of Chest Physicians, the American Thoracic Society and the National Association for Medical Direction of Respiratory Care meet with staff from the Centers for Medicare and Medicaid Services (CMS) on August 24 to discuss concerns over CMS’ proposal to reduce payment for pulmonary rehabilitation (PR) services in the hospital outpatient setting from $63 to $38, effective January 1, 2012.
When CMS first set the payment rates for the new PR benefit, they used “proxy” data from long-standing codes G0237-39 in addition to including costs for other ancillary services that were determined to be part of the new comprehensive benefit. In CY 2010 the rate was $50; in CY 2011 the rate was $63. Now that CMS has actual data from the G0424 code they created specifically for the new benefit, they have revised their payment methodology which results in a proposed payment rate of $38 for CY 2012.
The Problem with CMS’ Analysis
In its discussions, the societies and organizations made it clear that there were numerous flaws in the data that CMS analyzed to come up with such a substantial reduction for PR from previous rates. Some of these include the following:
The pulmonary organizations believe there are two approaches CMS can take to correct the problem and produce a payment rate that is appropriate for the services being provided. One is short term; the other has a longer-term effect.
We also recommend CMS instruct hospitals to report PR services as a non-standard cost center for hospital cost reports filed after January 1, 2012. Currently CMS uses a standard cost center approach for almost all outpatient therapeutic services.
Some questions remain on how hospitals can accurately report the cost of the ancillary services associated with the comprehensive PR benefit as part of the bundled G-424 code. We are seeking clarification from CMS and will keep you informed as additional information is available. Also, don’t forget that there will be a presentation on “How to Bill for Pulmonary Rehabilitation” at our Tampa International Congress on November 8, 2011. So plan to attend and get the latest information “hot off the press.”