ASC Payment System Updates: January 2022

Weeks after finalizing payment rates and policy changes affecting Medicare services furnished in hospital outpatient and Ambulatory Surgical Center (ASC) settings for calendar year (CY) 2022, the Centers for Medicare & Medicaid Services (CMS) released updates to the ASC payment system, effective Jan. 1, 2022. Make sure your billing staff knows about these changes.

January 2022 ASC Payment System Changes

New Device Pass-Through Categories

Two new device pass-through categories are now in effect:

C1832 Autograft suspension, including cell processing and application, and all system components; J7 ASC payment indicator (PI)

C1833 Monitor, cardiac, including intracardiac lead and all system components (implantable); J7 ASC PI

Device Offset for C1833

Device offset represents a deduction from the ASC procedure payment for the applicable pass-through device. CMS determined that there are offsets associated with the costs of the device category described by HCPCS Level II code C1833. As such, in the ASC setting, always bill the device in the category described by C1833 with one of the following CPT® codes:

• 0525T  Insertion or replacement of intracardiac ischemia monitoring system, including testing of the lead and monitor, initial system programming, and imaging supervision and interpretation; complete system (electrode and implantable monitor), which is assigned to Outpatient Prospective Payment System (OPPS) ambulatory payment classification (APC) 5223 for CY 2022.
• 0526T  Insertion or replacement of intracardiac ischemia monitoring system, including testing of the lead and monitor, initial system programming, and imaging supervision and interpretation; electrode only, assigned to OPPS APC 5222 for CY 2022.
• 0527T Insertion or replacement of intracardiac ischemia monitoring system, including testing of the lead and monitor, initial system programming, and imaging supervision and interpretation; implantable monitor only, assigned to OPPS APC 5222 for CY 2022.

Device Offset for C1832

CMS determined that there are also offsets associated with the costs of the device category described by HCPCS Level II code C1832. When billing the device in the category described by C1832, always report it with one of the following CPT® codes:

• 15110 Epidermal autograft, trunk, arms, legs; first 100 sq cm or less, or 1% of body area of infants and children, assigned to OPPS APC 5054 for CY 2022.
• 15115 Epidermal autograft, face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits; first 100 sq cm or less, or 1% of body area of infants and children, assigned to OPPS APC 5054 for CY 2022.

You may bill the device in the category described by HCPCS Level II code C1832 with one of the following CPT® codes, but you must also use one of the preceding codes (15110, 15115):

• 15100 Split-thickness autograft, trunk, arms, legs; first 100 sq cm or less, or 1% of body area of infants and children (except 15050), assigned to OPPS APC 5054 for CY 2022.
• 15120 Split-thickness autograft, face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits; first 100 sq cm or less, or 1% of body area of infants and children (except 15050), assigned to OPPS APC 5055 for CY 2022.

ASC Covered Procedure List Policy Revamped

As discussed in the 2022 OPPS/ASC final rule, CMS is reinstating the criteria for adding procedures to the ASC Covered Procedures List (ASC CPL) that were in place in CY 2020. After reviewing recommendations and comments on the 258 procedures proposed for removal from the ASC CPL, CMS decided to:

• Keep six procedures on the ASC CPL; three were already on the ASC CPL; three were proposed for removal (0499T, 54650, 60512).
• Remove 255 of the 258 procedures proposed for removal.

NOTE: ASC PI=N1 is a packaged procedure and is not separately billed by ASCs

ASC Payment – Drugs and Biologicals

Effective Jan. 1, 2022, there are 11 new drug and biological HCPCS Level II codes; three are deleted (C9082, C9083, J2505).

Drugs and Biologicals With Payments Based on Average Sales Price

For CY 2022, payment for nonpass-through drugs and biologicals continues to be made at a single rate of average sales price (ASP) plus 6 percent, which provides payment for both the acquisition cost and pharmacy overhead costs associated with the drug or biological.

Likewise, a single payment of ASP plus 6 percent continues to be made for OPPS pass-through drugs and biologicals to cover acquisition and pharmacy overhead costs of these pass-through items. Payments for drugs and biologicals based on ASPs will be updated quarterly as later quarter ASP submissions become available.

Retroactive Corrections to Payment Rates Allowed

CMS reserves the right to correct the payment rates of some drugs and biologicals based on the ASP methodology retroactively. These retroactive corrections typically occur quarterly. The list of drugs and biologicals with corrected payment rates will be available on the first date of the quarter.

Billing Skin Substitute Products

CMS packages the payment for skin substitute products that don’t qualify for hospital OPPS pass-through status into the OPPS payment for the associated skin substitute application procedure. The ASC payment system also has this policy.

Bill all OPPS pass-through skin substitute products (ASC PI=K2) in combination with one of the skin application procedures described by CPT® codes 15271-15278.

One new skin substitute HCPCS Level II code (Q4199) is active as of Jan. 1, 2022. The code is packaged and assigned to the low-cost skin substitute group. Note that you shouldn’t separately bill for packaged skin substitutes (ASC PI=N1) since packaged codes aren’t reportable under the ASC payment system.

Table 7 of CR 12553 lists the skin substitute products and their assignment as either a high-cost or a low-cost skin substitute product, when applicable.

Retracting a revision reported in CR 12451, CMS clarifies in CR 12553 that there has been no change to the long descriptor for HCPCS Level II code J1443 Injection, ferric pyrophosphate citrate solution (triferic), 0.1 mg of iron. The latest code descriptors for all HCPCS Level II codes are on the CMS HCPCS Quarterly Update website.

See MLN Matters article MM12553 for more information on Change Request 12553.

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Stacy Chaplain

Stacy Chaplain, MD, CPC, is a development editor at AAPC. She has worked in medicine for more than 23 years, with an emphasis on education, writing, and editing since 2015. Chaplain received her Bachelor of Arts in biology from the University of Texas at Austin and her doctorate in medicine from the University of Texas Medical Branch in Galveston. She is a member of the Beaverton, Ore., local chapter.

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