On March 10, 2014, a team from Illinois and Washington made a presentation to the Hospital Outpatient Payment (HOP) Panel that would move a series of codes from direct physician supervision to the general supervision category. Pat Schou, Executive Director of the Illinois Critical Access Hospital Network (ICAHN), Daniel Congreve, M.D. of Kewanee Hospital, Kewanee, IL and Robert Sinclair, M.D., Lincoln Hospital District #3, Davenport, WA made the trip to Maryland to present the following codes to the HOP Panel for consideration:
36430 Blood Transfusion Services
36593 Declot Vascular Devices
96401 Chemo anti-neo sq/IM
96402 Chemo horma anti/neo sq/IM
96409 Chemo IV push single drug
96411 Chemo IV push add/drug
96413 Chemo IV infusion/hr
96413 Chemo IV infusion add I hour
96416 Chemo prolong infusion with push
96417 Chemo IV infusion addl sequ
94667 Chest wall manipulation/percussion*
94668 Chest wall manipulation*
36600 Withdrawal arterial Blood*
86900 and 86901 Blood typing*
97597 Pulse lavage/wound cleansing
*Submitted through a comment letter by the Illinois Hospital Association.
The HOP Panel accepted their recommendation to move all of the above codes to general level supervision. This is a huge win for rural providers; however, the process is not finished:
1. The HOP Panel decision is a recommendation to CMS, who now has 30 days in which to render their preliminary decision on its website regarding these codes. There will be a 30 day public comment period on CMS’ preliminary decision.
2. NRHA will encourage its members to comment on the preliminary decision, particularly if the CMS decision on any or all of the above codes is negative. Clinician comments will be particularly helpful.
3. Once the 30 days of comments are over, CMS will review the comments and render a final decision as part of its sub-regulatory process posted on its webpage.
4. These decisions will likely be effective on July 1, 2014.
NRHA appreciates the combined efforts of Pat Schou, Daniel Congreve, M.D., Robert Sinclair, M.D., Kewanee Hospital, Illini Community Hospital, Illinois Hospital Association and Lincoln Hospital District #3 as rural providers nationwide will benefit from their work.