Recently, due heavily to improvements in medical technologies— which now allow for more complex procedures to be performed in an outpatient setting—combined with significant reductions in reimbursement for certain procedures in an OBL, many OBLs have launched ASCs and now operate in a hybrid OBL/ASC model. For example, the severe reductions in OBL-based reimbursement in the dialysis vascular access service arena in 2017 made it difficult for these facilities to survive, let alone thrive. In a hybrid model, the facility operates as an OBL on certain days of the week and as an ASC on the other days of the week. By moving to a hybrid model, these groups are able to take on additional and more complex procedures, thus providing a high-quality and convenient solution for their patients. This, in turn, simultaneously increases the volume and reimbursement for the providers and significantly improves the utilization and efficiency of the OBL/ASC.
While there has been a significant increase in Medicare-approved cardiology and vascular procedures that can be performed in an ASC recently, there still are many procedures that are not yet approved to be performed in an ASC. Thus, the two best options to perform such procedures in an ASC today would either be in a hybrid OBL/ASC or in an already existing multispecialty ASC that can be tailored to perform such specialized procedures. Due to continued advancements in medical technology, however, it is highly likely that Medicare will approve more complex cardiology and vascular procedures, such as aneurysm repairs and carotid stenting, to be performed in an ASC. When approved, single-specialty cardiology and vascular ASCs will be fully utilized and highly profitable.
If an OBL makes the decision to move to a hybrid OBL/ASC, it will have to tackle numerous issues to make the transition. These issues include, in most states, obtaining a certificate of need; complying with the federal and state fraud and abuse and self-referral laws; obtaining and maintaining an ASC state license; satisfying the Medicare Conditions for Coverage; and focusing on key operational and revenue cycle differences in an ASC as compared to an OBL, such as scheduling, registration, billing, coding and practice management.
Revenue Cycle and Coding Considerations
If an OBL makes the decision to move to a hybrid OBL/ASC, it is critical to place significant emphasis on training, particularly for the scheduling and medical coding functions. Given that the facility will be operating part time as an OBL and part time as an ASC, the scheduling team must be well-versed in the types of procedures that should be scheduled in an OBL as compared to an ASC, and be aware of the dates for each. Handling this correctly or incorrectly has a definite ripple effect on the rest of the revenue cycle and, ultimately, on reimbursement.
When an OBL adds in an ASC, it is critical that the facility has a highly experienced ASC coding team handling the work as ASC coding is significantly different from OBL coding. Ideally, the coders would all be ASC-certified and have significant cardiology and/or vascular experience to fully appreciate and manage the numerous differences.
For example, a procedure performed in an OBL, or place of service 11, would have only one claim coded and submitted for reimbursement. It would be on the professional or physician claim referred to as a CMS 1500 claim form. On the other hand, if a procedure were performed in the ASC, or place of service 24, two claims would need to be coded and submitted, with the professional claim on a CMS 1500 form and the facility claim on either a CMS 1450 form (UB 04) or a CMS 1500 form, depending on the payer’s requirements.
Further, device insertion or replacement codes such as pacemakers, implantable cardioverter-defibrillators (ICD), and event recorders have an ASC payment indicator of J8, which means that the procedure is considered device-intensive. Therefore, for an ASC, Medicare’s payment for the generator/supply is built in to the reimbursement of the procedure code billed by the facility. When used in an OBL, however, the same devices can be reimbursed separately by Medicare.