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Impacts of the 2024 CMS OPPS, ASC
& 340(B) Proposed Rule

 

Medicare 2024 OPPS & ASC Proposed Rule

We are excited to share Part 2 of the latest Medicare 2024 Proposed Rule updates relating to Outpatient Prospective Pay Schedule (OPPS), Ambulatory Surgery Center (ASC), and the 340 (B) Pharmacy Program for our Hospital Partners.Here we cover several items that could have a significant financial impact next year.

Outpatient Prospective Payment System Proposed Rule Changes

CMS proposes increasing the payment rate by 2.8% for items and services in which payments fall under the OPPS. Hospitals must meet the outpatient quality reporting requirements to be eligible and benefit from this updated payment rate.

340(B) Program

CMS is following the CY 2023 finalized policy and will be holding the current statutory default reimbursement rate of the 340B Drug Pricing Program for CY2024. That will have 340B acquired drugs reimbursed at the average sales price plus 6%.

CMS is also requesting feedback on establishing a new payment rule under the Inpatient Prospective Payment System that would support hospitals establishing and maintaining a buffer stock of essential medicines to provide for a more reliable supply chain. This could begin for cost reporting periods as early as January 1, 2024.

In a separate notice CMS has provided a proposed remedy for prior years payments as it relates to the 340(b) program. The following link is provided from the Federal Register on the Hospital Outpatient Prospective Payment System: Remedy for the 340B-Acquired Drug Payment Policy for Calendar Years 2018-2022 Proposed Rule (CMS 1793-P); https://www.federalregister.gov/public-inspection/2023-14623/medicare-program-hospital-outpatient-prospective-payment-system-remedy-for-the-340b-acquired-drug. There is also a CMS Fact Sheet associated to the Proposed Remedy for 340(b) payments provided below this newsletter along with other informational links. This comment period will also close on September 11th.

Hospital Price Transparency

CMS is looking to strengthen compliance (improve enforcement) and improve the public’s understanding and use of hospital information. In doing so it is proposing to modify the transparency requirements (45 CFR 180.50) and to update the enforcement provisions (45 CFR 180.70).

Hospital Outpatient/ASC/REH Quality Reporting Programs

CMS is proposing changes to and requesting comments on many of the outpatient-based quality reporting programs. For more information, see the OPPS and ASC Proposed Rule Fact Sheet.

 

What can you do?

As the healthcare landscape evolves, hospitals and medical practices must stay ahead of regulatory changes to safeguard their financial stability and maintain the highest level of patient care. The Medicare 2024 OPPS and ASC Payment System Proposed Rule bring both challenges and opportunities. This newsletter is just scratching the surface!

Our team at V2V Management Solutions can assist you in conducting a financial analysis to understand how these payment rate adjustments and quality metric changes might affect the bottom line of your medical practice environments and your employed physician arrangements. We can help identify operational opportunities and strategies to optimize revenue while maintaining high-quality patient care.

As always, there is a 60-day comment period to provide feedback on the proposed rule, which closes on September 11, 2023. Comments related to the OPPS and ASC Proposed Rule changes can be submitted at: https://www.regulations.gov/ (in commenting please refer to file code CMS-1786-P if responding to the OPPS/ASC Proposed Rule and file code CMS-1793-P if responding to the 340(B) Remedy Proposed Rule).

We are committed to being your partner in navigating these changes. Don't let regulatory changes hinder your ability to provide exceptional patient care while maintaining a financially stable practice.Contact us today and let us help you navigate upcoming changes and discuss operational opportunities that may exist within your practice!

 

For More Information Follow These Links

Medicare OPPS and ASC Proposed Rule Fact Sheet https://www.cms.gov/newsroom/fact-sheets/cy-2024-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-centerHospital Outpatient Prospective Payment System: Remedy for the 340B-Acquired Drug Payment Policy for Calendar Years 2018-2022 Proposed Rule (CMS 1793-P) Fact Sheet https://www.cms.gov/newsroom/fact-sheets/hospital-outpatient-prospective-payment-system-remedy-340b-acquired-drug-payment-policy-calendarMedicare Physician Fee Schedule Proposed Rule Fact Sheet https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-proposed-ruleMedicare Shared Savings Program Proposed Rule Fact Sheet https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-proposed-rule-medicare-shared-savings-program

Improve your Cashflow!

Optimize your Revenue Cycle with our Revenue Advantage SM

Understanding all the various nuances of an ever changing reimbursement landscape can seem like a daunting task. The above CMS topics are just a drop in the bucket.

As you look to take your medical practice network to new heights of success, consider conducting a revenue cycle optimization review as a cornerstone to achieving financial success.Below are a focus areas to consider as part of an ongoing effort to ensure your revenue cycle is performing optimally:

  • regular KPI reporting and benchmarking
  • claims management (accuracy, timeliness, and routine payer analysis)
  • registration accuracy and financial policies
  • technology system integrations and workflows
  • staff training and communications
  • revenue integrity (charge capture and coding accuracy)
  • compliance
  • patient engagement
  • auditing and continuous improvements

Let's chat about where you are and what area of focus may be most important for you to advance your revenue cycle focus. Schedule a complimentary conversation with Michelle to talk through developing your One Page Action Plan (OPAP) to assist in focusing you and your team.  Click below to schedule your discussion today or email us for more information.

Schedule your Complimentary One Page Action Plan Discussion

 

V2V is here to help

Lets Connect:Irv Barnett, Founder: [email protected]   208-717-3941Michelle Wier, Founder: [email protected]  208-717-3943

Disclaimer: V2V Management Solutions is a healthcare consulting firm. We are not licensed attorneys or certified public accountants. This guide is not intended to replace legal or financial advice from your trusted resources. Before acting on any information provided, check with the appropriate legal or financial team. Healthcare is a constantly evolving landscape; be sure to research for the most current information. The provided content consists of key takeaways on information published in the above referenced articles, facts sheets, and our personal/professional experiences in healthcare management.

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“Knowing it is time to reshape your current reality is the first step to transformation. When we contacted V2V, our goal was to innovate our clinic network from all aspects; integration, structure, financial controls and leadership. Michelle and her team at V2V helped us develop a well-defined plan. In transformational management one hears Quality times Acceptance equals Results (Q*A = R). Along with the quality of recommendations, V2V worked diligently to garner both input and acceptance from providers and staff. This is what I believe will ensure long-term, sustainable success for our clinics in a very uncertain time..”

Steven D. Febus – Chief Financial Officer, Pullman Regional Hospital

“Knowing it is time to reshape your current reality is the first step to transformation. When we contacted V2V, our goal was to innovate our clinic network from all aspects; integration, structure, financial controls and leadership. Michelle and her team at V2V helped us develop a well-defined plan. In transformational management one hears Quality times Acceptance equals Results (Q*A = R). Along with the quality of recommendations, V2V worked diligently to garner both input and acceptance from providers and staff. This is what I believe will ensure long-term, sustainable success for our clinics in a very uncertain time..”

Steven D. Febus – Chief Financial Officer, Pullman Regional Hospital

“Michelle Wier, CMPE, worked with our EMS program for a year, providing interim financial management at a crucial time for our hospital district based agency. Her exemplary work included budget and tool development, redesign of our financial statements, and a compensation analysis for all EMS positions. She helped provide crucial accountability for our internal accounting systems, contract negotiation support and a streamlining of our in house processes and reporting structures. I highly recommend her work product and greatly appreciate her astuteness and work ethic.”

J. Michael Edwards, DDS, MD, FACS – Commissioner, San Juan County Public Hospital District #1 San Juan Island EMS and MedEvac

“Knowing it is time to reshape your current reality is the first step to transformation. When we contacted V2V, our goal was to innovate our clinic network from all aspects; integration, structure, financial controls and leadership. Michelle and her team at V2V helped us develop a well-defined plan. In transformational management one hears Quality times Acceptance equals Results (Q*A = R). Along with the quality of recommendations, V2V worked diligently to garner both input and acceptance from providers and staff. This is what I believe will ensure long-term, sustainable success for our clinics in a very uncertain time..”

Steven D. Febus – Chief Financial Officer, Pullman Regional Hospital

“With excitement and enthusiasm I announce the transition of Wier Management Solutions to V2V Management Solutions. I’m honored to partner with some of the industry’s best “Transformationists,” who will assist our clients in realizing and enhancing the value within their organizations.”

Michelle Wier – President, Wier Management Solutions, Inc.

“Knowing it is time to reshape your current reality is the first step to transformation. When we contacted V2V, our goal was to innovate our clinic network from all aspects; integration, structure, financial controls and leadership. Michelle and her team at V2V helped us develop a well-defined plan. In transformational management one hears Quality times Acceptance equals Results (Q*A = R). Along with the quality of recommendations, V2V worked diligently to garner both input and acceptance from providers and staff. This is what I believe will ensure long-term, sustainable success for our clinics in a very uncertain time..”

Steven D. Febus – Chief Financial Officer, Pullman Regional Hospital

“Knowing it is time to reshape your current reality is the first step to transformation. When we contacted V2V, our goal was to innovate our clinic network from all aspects; integration, structure, financial controls and leadership. Michelle and her team at V2V helped us develop a well-defined plan. In transformational management one hears Quality times Acceptance equals Results (Q*A = R). Along with the quality of recommendations, V2V worked diligently to garner both input and acceptance from providers and staff. This is what I believe will ensure long-term, sustainable success for our clinics in a very uncertain time..”

Steven D. Febus – Chief Financial Officer, Pullman Regional Hospital

“Knowing it is time to reshape your current reality is the first step to transformation. When we contacted V2V, our goal was to innovate our clinic network from all aspects; integration, structure, financial controls and leadership. Michelle and her team at V2V helped us develop a well-defined plan. In transformational management one hears Quality times Acceptance equals Results (Q*A = R). Along with the quality of recommendations, V2V worked diligently to garner both input and acceptance from providers and staff. This is what I believe will ensure long-term, sustainable success for our clinics in a very uncertain time..”

Steven D. Febus – Chief Financial Officer, Pullman Regional Hospital