The ACC submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on Sept. 13, providing feedback and raising concerns on several issues regarding the calendar year 2023 proposed Outpatient Prospective Payment (OPPS) Rule.

The issues raised/comments offered include:

• The myriad of complexities that should be considered and addressed as CMS attempts to develop a framework for reimbursement of software as a service codes.
• Urging modifications of some cardiac imaging codes to higher, more appropriate ambulatory payment classifications.
• Support for the best available ambulatory payment classification placement of Fractional Flow Reserve Derived from Computed Tomography providing the optimal reimbursement available for this service.
• Recommending continuation of direct supervision of cardiac rehabilitation and pulmonary rehabilitation being allowed via telecommunication technology following the Public Health Emergency (PHE) and the statutorily mandated 151-day post-PHE period.
• Support for CMS' proposal to average the reimbursement of placebo devices with real devices in clinical studies creating a uniform payment for all to ensure the payment documentation does not break the blind for the patients in these studies damaging the validity of the study.
• Suggestions for improvements on certain aspects of the new Rural Emergency Hospital Quality Reporting program.
• Support for creation of a complexity adjustment update to the Ambulatory Surgical Center payment system.

Read ACC's full comment letter here. CMS will be issuing a final rule by Nov. 2.

Before the final rule is issued, ACC members can join their colleagues in Washington, DC, for ACC Legislative Conference 2022, taking place Oct. 16-18, to learn about ACC's policy and legislative issues. Register now!

Clinical Topics: Cardiovascular Care Team

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Fractional Flow Reserve, Myocardial, Medicare, Outpatients, Cardiac Rehabilitation, Public Health, Technology, Software

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