The Centers for Medicare and Medicaid Services (CMS) released the calendar year 2023 Medicare Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) final rule Nov. 1. An area of focus in the HOPPS rule for radiology providers is the reimbursement of software as a service (SaaS) procedures.
CMS originally proposed to establish Healthcare Common Procedure Coding System (HCPCS) C-codes (temporary pricing codes valid only for Medicare) to describe the add-on SaaS codes as standalone services, including LiverMultiScan, Optellum LCP and QMRCP. Some commenters, including the Medicare Payment Advisory Commission (a non-partisan independent congressional advisory body on the Medicare program), opposed separate payment for these services, citing that paying separately undermines the integrity of the prospective payment system payment bundles. In the final rule, CMS felt it was appropriate to exempt certain SaaS add-on codes from the general policy of packaging add-on services, and it is appropriate to assign these codes to identical ambulatory payment classifications (APCs) and status indicator assignments as their standalone codes. Table 69 in the final rule outlines the SaaS procedure CPT® codes with their APC placements and status indicators.
The American College of Radiology® (ACR®) is reviewing the final rule and will release a detailed summary outlining radiology-specific topics. If you have any questions about SaaS, email Kimberly Greck, ACR Economic Policy Analyst, or Christina Berry, ACR Team Lead, Economic Policy.