The Centers for Medicare & Medicaid Services (CMS) is soliciting nominations for new members to the Advisory Panel on Hospital Outpatient Payment to fill five current vacancies. The Panel is charged with advising the HHS Secretary and the CMS Administrator on the clinical integrity of the Medicare hospital outpatient Ambulatory Payment Classification groups and their associated weights, along with supervision levels for hospital outpatient services. CMS will consider nominations received by December 31, 2013.
As a result of the partial government shutdown, CMS is warning that it may delay until late November a series of major final rules setting a wide range of Medicare payment rates and policies for 2014. While CMS usually releases the final calendar year updates by November 1st each year, CMS is now saying that the 16-day government shutdown could push back the release date of the following rules to November 27th (or potentially later):
• CY 2014 Changes to the Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment System;
• Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2014;
• Medicare Program; End-Stage Renal Disease (ESRD) Prospective Payment System, Quality Incentive Program, and Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS); and
• CY 2014 Home Health Prospective Payment System Final Rule.
This timeline could leave providers, suppliers, and other health care entities only a few weeks to prepare for potentially sweeping changes before they go into effect on January 1, 2014 (although certain provisions have different effective dates). For instance, stakeholder are awaiting final disposition of CMS proposals to, among many other things: expand payment bundles under the HOPPS; cut physician fee schedule reimbursement for more than 200 codes if the Medicare physician office payment exceeds the HOPPS or ASC payment; systematically reexamine payment amounts under the Clinical Laboratory Fee Schedule; establish a centralized review process for Investigational Device Exemption (IDE) coverage decisions; reduce ESRD rates by 9.4%; and revise various DMEPOS payment policies.
CMS has published a notice correcting technical errors that appeared in the July 19, 2013 proposed rule updating the Medicare Hospital Outpatient Prospective Payment System (OPPS) and the ambulatory surgical center payments for CY 2014. In addition to making revisions to specific ambulatory payment classifications, the technical corrections result in changes to the proposed OPPS relative payment weights and conversion factor (which generally have the impact of reducing payment rates). CMS is accepting comments on the technical corrections until September 16, 2013. Updated payment files are posted here.
On July 19, 2013, CMS published a proposed rule that would update Medicare outpatient prospective payment system (OPPS) and ambulatory surgical centers (ASCs) policies and rates for CY 2014. Key provisions of the proposed rule include the following:
- CMS proposes to update the OPPS market basket by 1.8% for 2014, which reflects a 2.5% hospital market basket increase, minus a 0.4% multifactor productivity (MFP) adjustment and an additional 0.3% reduction (both mandated by the ACA). The OPPS update is subject to other adjustments, including a 2% reduction for hospitals that do not meet quality reporting requirements.
- CMS proposes larger payment bundles to maximize hospitals’ incentives to provide care in an efficient manner, including by encouraging hospitals “to effectively negotiate with manufacturers and suppliers to reduce the purchase price of items and services or to explore alternative group purchasing arrangements.” Specifically, CMS proposes to package the following seven new categories of supporting items and services into the procedural ambulatory payment classification (APC) payment: (1) Drugs, biologicals, and radiopharmaceuticals that function as supplies when used in a diagnostic test or procedure; (2) drugs and biologicals that function as supplies or devices when used in a surgical procedure; (3) certain clinical diagnostic laboratory tests; (4) procedures described by add-on codes; (5) ancillary services assigned status indicator “X”; (6) diagnostic tests on the bypass list; and (7) device removal procedures. Note that in some cases separate payment is permitted if these services are reported alone on a claim.
- In a separate provision, CMS proposes to create 29 all-inclusive, “comprehensive APCs” to replace 29 existing device-dependent APCs and prospectively pay for device-dependent services associated with 136 HCPCS codes. CMS is proposing to package into the comprehensive APCs all “adjunctive services” provided during the delivery of the comprehensive service, including: diagnostic procedures, laboratory tests and other diagnostic tests, and treatments that assist in the delivery of the primary procedure; visits and evaluations performed in association with the procedure; uncoded services and supplies used during the service; outpatient department services delivered by therapists as part of the comprehensive service; durable medical equipment, prosthetic and orthotic items, and supplies when provided as part of the outpatient service; and any other components reported by HCPCS codes that are provided during the comprehensive service (except charges that cannot be covered by Medicare Part B or that are not payable under the OPPS).
- CMS proposes to collapse the current five levels of outpatient visit codes into a single code for each unique type of outpatient hospital visit.
- CMS proposes to continue a policy adopted last year setting OPPS payment for separately payable drugs and biologicals without pass-through status at average sales price (ASP) plus 6% (which it refers to as the "statutory default" rate), without an adjustment for pharmacy overhead costs. The proposed 2014 threshold for separate payment for outpatient drugs would be a cost per day that exceeds $90, compared to $80 in 2013.
- With regard to ASC policy, CMS is proposing to increase ASC payment rates by 0.9%, which is derived from a 1.4% inflation update reduced by a 0.5% MFP adjustment. ASCs that do not meet quality reporting requirements would be subject to a 2% payment reduction. CMS also proposes that ancillary or adjunctive services that would be packaged under the OPPS also would be packaged under the ASC payment system for CY 2014.
- In addition, the proposed rule addresses, among many other things: refinements to the Hospital Outpatient Quality Reporting Program, the ASC Quality Reporting Program, and the Hospital Value-Based Purchasing Program; payment for partial hospitalization services; a requirement that individuals furnish “incident to” hospital or critical access hospital outpatient services in compliance with state law; and changes to Quality Improvement Organization eligibility and contracting rules
CMS will accept comments on the proposed rule until September 6, 2013.
On July 19, 2013, the Centers for Medicare & Medicaid Services (CMS) published its proposed rule updating Medicare physician fee schedule (PFS) rates and polices for calendar year (CY) 2014. CMS projects that PFS payments will be reduced by approximately 24.4% in 2014, largely due to the statutory Sustainable Growth Rate (SGR) update formula (although Congress is expected to eventually take action to block the automatic cuts, as it has in the past). The rule also includes a number of significant policy proposals, including the following highlights:
- Under the proposed rule, CMS projects an estimated 2014 conversion factor of $25.7109, adjusted to $26.8199 to include a budget neutrality adjustment, compared to the 2013 conversion factor of $34.0230. As noted, Congress could override the SGR formula on either a temporary or permanent basis, but the timing and scope of any such action is uncertain. Reimbursement changes for individual procedures would vary based on numerous other policy proposals and updates.
- Under its potentially misvalued code initiative, CMS is proposing to reduce PFS rates for more than 200 codes if Medicare physician office payment exceeds the payment in the outpatient hospital department or ambulatory surgical center (ASC) setting. CMS proposes limiting PFS payment in such cases to the total payment that Medicare would make to the practitioner and the facility when the service is furnished in a hospital outpatient department or ASC. Certain services would be exempt from this provision, including services without separate hospital outpatient prospective payment system (OPPS) payment rates and codes already subject to cuts pursuant to the Deficit Reduction Act imaging cap, among others). CMS estimates that this policy would have the biggest negative impact on allowed charges for independent laboratory PFS payments, radiation therapy center services, and pathology services. CMS also proposes to examine other specific codes as part of the agency’s ongoing review of misvalued codes.
- CMS proposes to make payments for non-face-to-face complex chronic care management services for Medicare beneficiaries who have multiple (two or more) significant chronic conditions. This provision would be implemented in 2015 to provide sufficient time to develop and obtain public input on the standards necessary to demonstrate the capability to provide these services.
- CMS proposes to modify the definition of eligible telehealth originating sites to include health professional shortage areas (HPSAs) located in rural census tracts of urban areas as determined by the Office of Rural Health Policy, which CMS expects to result in the inclusion of additional HPSAs as areas for telehealth originating sites. CMS also proposes adding transitional care management services to the list of eligible Medicare telehealth services.
- CMS proposes to continue implementation of the physician value-based payment modifier (Value Modifier), which was mandated by the Affordable Care Act (ACA) to reward physicians for providing higher quality and more efficient care. The Value Modifier is being phased in from CY 2015 to CY 2017, with CY 2013 serving as the initial performance period for the CY 2015 Value Modifier. In the proposed 2014 rule, CMS calls for the value modifier to apply to groups of 10 or more eligible physicians in 2016 (compared to groups of 100 or more in 2015), and increases the amount of payment at risk from 1% to 2% in 2016. CMS also proposes to refine the methodologies used to calculate the value-based payment modifier to better identify both high and low performers for upward and downward payment adjustments.
- CMS proposes to amend the “incident to” regulations to require that services and supplies be furnished in accordance with applicable state law, and that the individual performing “incident to” services meet any applicable requirements to provide the services, including state licensure requirements. CMS is proposing this policy to ensure that auxiliary personnel providing services to Medicare beneficiaries incident to the services of other practitioners do so in accordance with applicable state requirements, and to ensure that Medicare payments can be recovered when such services are not furnished in compliance with the state law.
- CMS proposes a process to systematically reexamine payment amounts under the Clinical Laboratory Fee Schedule (CLFS) to determine if changes in technology for the delivery of that service (e.g., changes to the tools, machines, supplies, labor, instruments, skills, techniques, and devices by which laboratory tests are produced and used) warrant an adjustment to the payment amount. Beginning with the CY 2015 PFS proposed rule, CMS would identify the test code, discuss how it has been impacted by technological changes, and propose an associated payment adjustment. CMS would solicit comments, and any payment adjustment would be adopted in the final rule, beginning with the CY 2015 final rule. CMS would first examine the codes that have been on the CLFS the longest and then work forward, over multiple years, until all of the codes on the CLFS have been reviewed.
- CMS proposes a centralized review process under which a single entity would be responsible for making Investigational Device Exemption (IDE) coverage decisions. The rule also would establish minimum standards for IDE studies and trials for which Medicare coverage of devices or routine items and services is provided (including pivotal study and superiority study design criteria).
- CMS proposes to apply the outpatient therapy cap limitations and related policies to outpatient therapy services furnished in a critical access hospital beginning on January 1, 2014, in conformance with the American Taxpayers Relief Act (ATRA).
- The sweeping rule also addresses, among many other things: updates to the geographic practice cost indices (GPCIs) and revisions to the weights assigned to each GPCI to increase the weight of work and reduce the weight of practice expense; revisions to the calculation of the Medicare Economic Index (MEI); revisions to the Physician Quality Reporting System (PQRS) and the Electronic Health Record (EHR) Incentive program; revisions to regulations regarding liability for overpayments to conform to ATRA provisions with regard to the timing of the triggering event for the ‘‘without fault’’ and ‘‘against equity and good conscience’’ presumptions; and updates to the ambulance fee schedule regulations to conform with statutory requirements.
The comment deadline is September 6, 2013.
CMS has posted estimated hospital-specific charges and average Medicare payments for 30 Ambulatory Payment Classification (APC) Groups paid under the Medicare Outpatient Prospective Payment System (OPPS) for calendar year 2011. National and state-level summaries are also available.
CMS has announced that the second semi-annual meeting of the Advisory Panel on Hospital Outpatient Payment for 2013 will take place on August 26 and 27, 2013. The purpose of the panel is to advise CMS on the clinical integrity of the Ambulatory Payment Classification groups and their associated weights, and hospital outpatient therapeutic services supervision issues. The deadline for presentations and comments is Friday, July, 19, 2013. Registration runs from July 8, 2013 through August 9, 2013 to attend in person (no registration is required for participants who plan to view the meeting via webcast).
MedPAC has released its annual report to Congress on Medicare Payment Policy, including payment update recommendations for all the major Medicare FFS payment systems and limited Medicare Advantage (MA) recommendations. The report also includes data on the status of the MA and Medicare Part D programs, including information about enrollment, plan options, and beneficiary cost-sharing. Note that while MedPAC’s recommendations are not binding, Congress and CMS often take into account MedPAC’s assessments when updating Medicare payment policies. Major recommendations include the following (many of which were included in previous reports):
- Congress should increase payment rates for inpatient and outpatient hospital prospective payment systems by 1%, and require the difference between the statutory update and the recommended 1% update be used to offset payment increases due to documentation and coding changes and to recover past overpayments.
- Congress should repeal the sustainable growth rate (SGR) system for physician services and replace it with a 10-year path of statutory fee-schedule updates. This proposal, first offered in October 2011, would combine a freeze in payment levels for primary care and, for all other services, annual payment reductions followed by a freeze. MedPAC also endorsed the collection of data to establish more accurate work and practice expense values; budget-neutral changes to improve data on which relative value unit weights are based and to redistribute payments to underpriced services, and changes to the structure of accountable care organization shared savings payments.
- Congress should eliminate the ambulatory surgical center (ASC) payment update for 2014, require ASCs to submit cost data, and direct the Secretary to implement a value-based purchasing program for ASCs by 2016.
- Congress should eliminate the skilled nursing facility market basket update, and direct the Secretary to revise the prospective payment system for SNFs and begin a process of rebasing payment as soon as practicable.
- MedPAC reiterates previous recommendations to rebase home health rates, eliminate the market basket update, revise the home health case-mix system to rely on patient characteristics to set payment for therapy and nontherapy services, establish a per episode copay for home health episodes that are not preceded by hospitalization or post-acute care use, and expand program integrity efforts.
- Congress should eliminate the update to hospice rates for FY 2014 and adopt a series of previous MedPAC recommendations addressing payment and program integrity reforms.
- Congress should eliminate the 2014 updates for outpatient dialysis services, inpatient rehabilitation facilities, and long-term care hospitals.
- With regard to Medicare Advantage, Congress should allow the authority for most MA chronic care special needs plans (SNPs) to expire (with certain exceptions) and allow MA plans to enhance benefit designs for individuals with specific chronic or disabling conditions. MedPAC also recommends that Congress permanently reauthorize dual-eligible special needs plans (D–SNPs) that assume clinical and financial responsibility for Medicare and Medicaid benefits (with certain changes) and allow the authority for all other D–SNPs to expire.
CMS is hosting the next semi-annual meeting of the Advisory Panel on Hospital Outpatient Payment for 2013 on March 11, 2013. The purpose of the Panel is to advise the HHS Secretary and the CMS Administrator on the clinical integrity of ambulatory payment classification groups and their associated weights, and hospital outpatient therapeutic supervision issues. The deadline for presentations and comments is January 25, 2013, and the hardcopy of the presentation must be received by February 1, 2013. The meeting registration deadline is February 22, 2013.
** Note that due to an “unexpected low response to requests for presentations,” CMS has cancelled the previously-scheduled March 12 session, and the meeting will not be onsite at CMS headquarters; it will be conducted electronically via webcast, teleconference, and/or webinar.
CMS Final Decisions on Recommendations of the Hospital Outpatient Payment Panel on Supervision Levels for Select Services
CMS has released its Final Decisions on the August 2012 Recommendations of the Hospital Outpatient Payment Panel on Supervision Levels for Select Services. The document provides CMS’s final determinations regarding the appropriate supervision levels for 29 individual hospital outpatient therapeutic services, effective January 1, 2013. CMS has determined that 22 of the considered services may be furnished with a minimum of general supervision and the remaining 7 services will maintain their current designation as non-surgical extended duration therapeutic services.
On November 15, 2012, the Centers for Medicare & Medicaid Services (CMS) published its publishing its final rule with comment period updating Medicare payment and other policies for the hospital outpatient prospective payment system (OPPS) and ambulatory surgical centers (ASCs) for CY 2013. The rule also updates Medicare quality reporting program policies and various other Medicare policies. Key provisions of the final rule include the following:
- The rule will increase 2013 OPPS rates by 1.8% compared to 2012 levels (although the impact on particular procedures will vary). This update reflects a hospital market basket increase of 2.6%, which is reduced under two Affordable Care Act (ACA) provisions – a 0.1 percentage point reduction and a 0.7% “multi-factor productivity” (MFP) adjustment/reduction. The OPPS update is subject to other adjustments, including a 2 percentage point reduction for hospitals that do not meet quality reporting requirements.
- Effective for 2013, CMS will determine OPPS relative weights using the geometric mean costs of services within an Ambulatory Payment Classification, rather than median costs. CMS expects this change will have a limited payment impact on most providers, but believes it better encompasses variations in costs and aligns with the inpatient PPS methodology.
- CMS will set OPPS payment for separately payable drugs and biologicals without pass-through status at average sales price (ASP) plus 6% (which it refers to as the “statutory default” rate), compared to the current ASP plus 4%. Notably, CMS will not make an adjustment for pharmacy overhead costs in 2013 to reflect the redistribution of package costs, as it had for 2010 through 2012. The final 2013 threshold for separate payment for outpatient drugs is a cost per day that exceeds $80, compared to $75 in 2012. CMS also adopted a special payment adjustment policy to account for the costs of radioisotopes derived from non-highly enriched uranium sources.
- With regard to ASC policy, CMS will increase ASC payment rates by 0.6%, which is derived from a 1.4% inflation update reduced by an MFP adjustment of -0.8%.
- The final rule makes refinements to several Medicare quality programs, including the Hospital Outpatient Quality Reporting Program, the ASC Quality Reporting Program, and the Inpatient Rehabilitation Facility Quality Reporting Program.
- CMS is clarifying the application of the supervision regulations to physical therapy, speech-language pathology, and occupational therapy services that are furnished in OPPS hospitals and critical access hospitals (CAHs). CMS also is extending nonenforcement of the requirement for direct supervision of outpatient therapeutic services furnished in CAHS and small rural hospitals with 100 or fewer beds for one final year through CY 2013 (CMS anticipates that this will be the final year of the extension).
- CMS adopted changes to the regulations regarding payment for new technology intraocular lens (NTIOLs) to require more stringent labeling and clinical outcomes evidence to support NTIOL applications.
- The final rule also addresses, among other things, payment for partial hospitalization services; revisions to the electronic reporting pilot for the Electronic Health Record Incentive Program; changes to regulations governing Quality Improvement Organizations (including the secure transmittal of electronic medical information, beneficiary complaint resolution, and notification processes); and a discussion of public comments related to potential changes to the Part A to Part B Rebilling Demonstration and hospital observation services policy.
CMS will accept comments on certain provisions, including payment classifications assigned to certain HCPCS codes and other specified provisions, until December 31, 2012.
The Centers for Medicare & Medicaid Services (CMS) has sent several final Medicare calendar year 2013 payment rules to the White House Office of Management and Budget (OMB) for final regulatory clearance. Rules under review will establish final 2013 payment and other policies under the Medicare physician fee schedule, hospital outpatient prospective payment system,, home health prospective payment system (PPS), and end-stage renal disease PPS. Copies of the rules are not available at this point, but they are expected to go on display at the Federal Register in the coming days.
CMS has released updated data on Medicare payments to hospitals for commonly-performed outpatient procedures as part of its initiative to make more cost and quality data available to consumers. The updated hospital outpatient department information reflects calendar year 2011 data.
CMS Invites Comments on Preliminary Supervision Level Decisions for Selected Hospital Outpatient Services
The Centers for Medicare & Medicaid Services (CMS) is seeking comments on its preliminary decisions on supervision levels for select Medicare hospital outpatient services, based on recommendations of the Hospital Outpatient Payment Panel at its meeting in August 2012. CMS proposes accepting the Panel’s recommendations that 15 services be changed from direct supervision to general supervision, including codes related to vaccine administration, blood collection, catheter insertion, and intravenous infusion, among others. A number of the Panel’s recommendations were not accepted because CMS views the services as either involving physician assessment or providing a significant potential for patient complications. CMS will accept public comment on the proposed decisions through October 24, 2012. CMS will post final decisions after considering any comments received, and the decisions will be effective on January 1, 2013.
CMS is soliciting nominations for a total of 42 voting and nonvoting members of the Medicare Evidence Development & Coverage Advisory Committee (MedCAC), which advises CMS on the adequacy of scientific evidence available to CMS for Medicare “reasonable and necessary” determinations. Nominations must be received by September 24, 2012. CMS also is seeking nominations for two new members to the Advisory Panel on Hospital Outpatient Payment (HOP), which advises the agency on the clinical integrity of the Ambulatory Payment Classification (APC) groups and their associated weights, and supervision of hospital outpatient services. Nominations are due by October 23, 2012.
The Centers for Medicare & Medicaid Services (CMS) has issued a proposed rule that would update Medicare payment and other policies for the hospital outpatient prospective payment system (OPPS) and ambulatory surgical centers (ASCs) for calendar year (CY) 2013. The proposed rule also would update Medicare inpatient rehabilitation facility (IRF) quality reporting program policies and various other Medicare policies. The official version of the rule is scheduled to be published in the Federal Register on July 30, 2012. CMS will accept comments on the rule until September 4, 2012. Key provisions of the proposed rule include the following:
- The rule would increase 2013 OPPS rates by 2.1% compared to 2012 levels (although the impact on particular procedures would vary). This update reflects a hospital market basket increase of 3.0%, which is reduced under two Affordable Care Act (ACA) provisions – a 0.1 percentage point reduction and an estimated 0.8% “multi-factor productivity” (MFP) adjustment/reduction. The OPPS update is subject to other adjustments, including a 2 percentage point reductions for hospitals that do not meet quality reporting requirements. For 2013, CMS proposes to determine OPPS relative weights using the geometric mean costs of services within an Ambulatory Payment Classification, rather than median costs, which CMS expects would have a limited payment impact on most providers.
- CMS proposes setting OPPS payment for separately payable drugs and biologicals without pass-through status at average sales price (ASP) plus 6% (which it refers to as the “statutory default” rate), compared to the current ASP plus 4%. Notably, CMS is not proposing to make an adjustment for pharmacy overhead costs in 2013 to reflect the redistribution of package costs, as it had for 2010 through 2012. The proposed 2013 threshold for separate payment for outpatient drugs would be a cost per day that exceeds $80, compared to $75 in 2012. CMS also proposes a special payment adjustment policy for radioisotopes derived from non-highly enriched uranium sources.
- With regard to ASC policy, CMS is proposing to increase ASC payment rates by 1.3%, which is derived from a 2.2% inflation update reduced by an MFP adjustment of -0.9%. ASC payment rates for CY 2013 will represent 57% of rates for the same services under the OPPS. CMS is soliciting comments on development of an ASC-specific inflation index in place of the current Consumer Price Index for All Urban Consumers. CMS also proposes changes to the regulations regarding payment for new technology intraocular lens (NTIOLs) in the ASC setting to require more stringent labeling and clinical outcomes evidence to support NTIOL applications.
- CMS proposes changes to the IRF Quality Reporting Program, including updates to the quality measures that will impact annual prospective payment amounts in FY 2014 and procedural changes to the process for updating quality measures.
- In addition, the proposed rule addresses: refinements to the Hospital Outpatient Quality Reporting (OQR) Program and the ASC Quality Reporting (ASCQR) Program; payment for partial hospitalization services; potential changes to the Part A to Part B Rebilling Demonstration; revisions to the electronic reporting pilot for the Electronic Health Record Incentive Program; clarification of the application of the supervision regulations to physical therapy, speech-language pathology, and occupational therapy services furnished in OPPS hospitals and critical access hospitals; and changes to regulations governing Quality Improvement Organizations, including the secure transmittal of electronic medical information, beneficiary complaint resolution and notification processes.
CMS has sent several major calendar year 2013 proposed Medicare payment rules to the White House Office of Management and Budget (OMB) for final regulatory clearance. Rules under consideration include the proposed Medicare outpatient hospital, ambulatory surgical center (ASC), end-stage renal disease, and home health prospective payment system rules for calendar year (CY) 2013, along with notices updating payment policies for inpatient rehabilitation facilities and hospices for fiscal year 2013. We also expect the CY 2013 proposed Medicare physician fee schedule rule to reach the OMB shortly. While the text of the regulations are not available at this point, we expect that they will be put on display at the Federal Register in the near future. We will be providing summaries of the rules in future updates.
Based on recommendations made by the Hospital Outpatient Payment Panel at meetings in February, CMS is changing the supervision level for select hospital outpatient services, effective July 1, 2012. Most of the services impacted by the update are psychotherapy codes, but CMS also is updating supervision requirements for certain immunization administration, smoking and tobacco use cessation counseling, and catheter insertion codes.
CMS has scheduled a meeting of the HOP Advisory Panel (formerly known as the Advisory Panel on Ambulatory Payment Classification (APC) Groups) on August 27-29, 2012. Among other things, the panel will address: whether procedures within an APC group are similar both clinically and in terms of resource use; APC group weights; packaging of hospital outpatient prospective payment system services and costs; and the appropriate supervision level (general, direct, or personal) for individual hospital outpatient therapeutic services. The deadline for submitting presentations and comments is July 27, 2012, and the meeting registration deadline is August 17, 2012.
CMS has published technical corrections to the final 2012 Medicare hospital outpatient prospective payment system (OPPS) rule, which was published November 30, 2011. The notice corrects the revenue code-to-cost center crosswalk and the packaging status of certain drug codes.