In the face of the progressive implementation of the Affordable Care Act (ACA), a significant
regulatory regime, and the Merit-Based Incentive Payment System (MIPS), the Centers for
Medicare and Medicaid Services (CMS) released its proposed 2017 hospital outpatient
department (HOPD) and ambulatory surgery center (ASC) payment rules on July 14, 2016,
and the physician payment schedule was released July 15, 2016. U.S. health care costs
continue to increase, occupying 17.5% of the gross domestic product (GDP) in 2014 and
surpassing $3 trillion in overall health care expenditure. Solo and independent practices face
unique challenges and many are being acquired by hospitals or larger groups. This transfer
of services to hospital settings is indisputably leading to an increase in the net cost to the
system.
Comparison of facility payments for interventional techniques in HOPD, ASC, and in-office
settings shows wide variation for multiple interventional techniques. Major discrepancies in
payment schedules are related to higher payments for hospitals than comparable treatments
in in-office settings and ASCs. In-office procedures, which have been converted to ASC
procedures, are reimbursed at as high as 1,366% higher than ASCs and 2,156% higher
than in-office settings. The Medicare Payment Advisory Commission (MedPAC) has made
recommendations on avoiding the discrepancies and site-of-service differentials in in-office
settings, hospital outpatient settings, and ASCs. These have not been implemented by CMS.
In addition, there have been slow reductions in reimbursements over the recent years, which
continue to accumulate, leading to significant reductions in payments
In conclusion, equalization of site-of-service differentials will simultaneously improve
reimbursement patterns for interventional pain management procedures, increase access
and quality of care, and finally, reduce costs for CMS, extending Medicare solvency.
Key words: Hospital outpatient departments, ambulatory surgery centers, physician inoffice services, interventional pain management, interventional techniques
Quality Assurance for Interventional Pain
Management Procedures in Private Practice