Alabama Advocacy for Cardiac & Pulmonary Rehabilitation

First I have to brag… Jennifer Murphy, Kathe Briggs, Stacey Jones, Jeanne Carlson Your voice in Washington, DC at DOTH Very effective requesting a bill that will allow CR & PR to remain under hospital outpatient reimbursement and NOT decrease by 40% if located off-campus Thanks for those who sent letters-it matters Thanks to Todd Brown & Anita Jones for leading Alabama push on this issue GRQ, LLC 4/5/2019

Site Location-Good Intentions Section 603 of the Bipartisan Budget Act (BBA) of 2015 - Reason for the need Provider-Based Departments (PBD) that move to off-campus location are paid under Physician Fee Schedule (PFS) Hospital PBD established off-campus prior to 11-2-15 are “excepted” (grandfathered) You may not be “safe” Hospital outpatient services moved or established at an off-campus location after that date are “non-excepted” GRQ, LLC 4/5/2019

Site Location-Unintended Consequences Medicare data illustrate hospitals are NOT purchasing MD practices for CR/PR revenue AACVPR proposes a bill that exempts any hospital off- campus services under a certain financial threshold would be reimbursed per outpatient (OPPS) and NOT per physician fee schedule (PFS) CR & PR located or established on-campus are NOT affected by Section 603 Are you sure you’re safe? GRQ, LLC 4/5/2019

2019 Medicare Reimbursement Rates Pulmonary Rehab–G0424 & SET for PAD–93668 Hospital outpatient setting On campus $ 56 (OPPS rate) Off campus-excepted location $ 56? (OPPS rate?) Off campus-non-excepted $ 23 (PFS rate) Physician office setting $ 23 (PFS rate) GRQ, LLC 4/5/2019

2019 Medicare Reimbursement Rates Respiratory Care Services - G0237-39 Hospital outpatient setting On campus $ 32 (OPPS rate) Off campus-excepted location $ 32? (OPPS rate?) Off campus-non-excepted $ 13 (PFS rate) Physician office setting $ 13 (PFS rate) GRQ, LLC 4/5/2019

2019 Medicare Reimbursement Rates Cardiac Rehabilitation Hospital outpatient setting – 93798 & 93797 On campus (both codes) $ 118 (OPPS) Off campus-excepted location $ 118? Off campus-non-excepted 93798 $ 47 (PFS) Off campus-non-excepted 93797 $ 24 (PFS) Physician office setting-93798 $ 47 (PFS) Physician office setting-93797 $ 24 (PFS) ICR is paid per hospital outpatient rate whether on or off-campus GRQ, LLC 4/5/2019

Off Campus Provider-Based Departments (PBDs) Campus: defined in 42 CFR 413.65 “Physical area immediately adjacent to provider’s main buildings…that are not strictly contiguous to main buildings but are located within 250 yards of main buildings, and any other areas determined on an individual case basis, by CMS regional office, to be part of provider’s campus.” GRQ, LLC 4/5/2019

Off Campus Provider-Based Departments (PBDs) Your legal-compliance dept is acutely aware of Section 603 and campus definition, but may not be aware of the devastating payment implications for CR/PR For 2019-2020, it appears CMS may have changed payment calculation for some off-campus outpatient services to lower $ amount American Hospital Association lawsuit has filed suit against CMS on Section 603. You WILL soon be asked to participate in AACVPR and Alabama advocacy efforts to correct this negative situation for CR, PR, & SET GRQ, LLC 4/5/2019

https://www.youtube.com/watch?v=Otbml6WIQPo&feature=youtu.be How a Bill Becomes a Law

AACVPR 2019 Day on the Hill Highlights https://www.youtube.com/watch?v=UaDr2a2L058&feature=youtu.be

SACPR Goes to DOTH Washington DC March 3-6, 2019