Facility Payments for Interventional Pain Management Procedures: Impact of Proposed Rules

In the face of the progressive implementation of the Affordable Care Act (ACA), a significantregulatory regime, and the Merit-Based Incentive Payment System (MIPS), the Centers forMedicare and Medicaid Services (CMS) released its proposed 2017 hospital outpatientdepartment (HOPD) and ambulatory surgery center (ASC) payment rules on July 14, 2016,and the physician payment schedule was released July 15, 2016. U.S. health care costscontinue to increase, occupying 17.5% of the gross domestic product (GDP) in 2014 andsurpassing $3 trillion in overall health care expenditure. Solo and independent practices faceunique challenges and many are being acquired by hospitals or larger groups. This transferof services to hospital settings is indisputably leading to an increase in the net cost to thesystem.Comparison of facility payments for interventional techniques in HOPD, ASC, and in-officesettings shows wide variation for multiple interventional techniques. Major discrepancies inpayment schedules are related to higher payments for hospitals than comparable treatmentsin in-office settings and ASCs. In-office procedures, which have been converted to ASCprocedures, are reimbursed at as high as 1,366% higher than ASCs and 2,156% higherthan in-office settings. The Medicare Payment Advisory Commission (MedPAC) has maderecommendations on avoiding the discrepancies and site-of-service differentials in in-officesettings, hospital outpatient settings, and ASCs. These have not been implemented by CMS.In addition, there have been slow reductions in reimbursements over the recent years, whichcontinue to accumulate, leading to significant reductions in paymentsIn conclusion, equalization of site-of-service differentials will simultaneously improvereimbursement patterns for interventional pain management procedures, increase accessand quality of care, and finally, reduce costs for CMS, extending Medicare solvency.Key words: Hospital outpatient departments, ambulatory surgery centers, physician inoffice services, interventional pain management, interventional techniques