Are you inquiring about the ASC payment indicators? If so - anything with a P2, P3 or R2 is considered 'office based.' I'm showing the 37220 and 37221 to be non-office based, by the way, so their payment is based on the OPPS.
Or are you inquiring about the logic (or lack thereof) behind the decisions? I think the Department of Health and Human Services has something to do with it but good luck sorting through the data. The Office of the Inspector General had HHS remove a number of procedures from ASC and/or hospital out patient payments back in 2003 because they determined they were procedures that should be done in an office and shouldn't be reimbursed anywhere else. I've always thought that the people responsible for these decisions should have hemorrhoids banded in an office sometime and see how they enjoyed that. Please post info here if you find out what committee/etc. makes these decisions. It would be helpful to know who to communicate with.
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