President's Column: First Quarter 2024
In July 2023, the Center for Medicare and Medicaid Services (CMS) released their 2024 Outpatient Prospective Patient System (OPPS) Proposed Rule, which included a 7% increase for G0277 hyperbaric oxygen treatment (per 30-minute segment) from $125.07 to $134.51 to go into effect Jan 1, 2024.
On Nov 7, 2023, it was called to the attention of UHMS leadership that CMS had released their 2024 OPPS Final Rule, which now reflected a 41.5% decrease in G0277 from $125.07 to $73.64. This difference between the Proposed and Final Rule was unexpected and without explanation.
UHMS leadership was very concerned and recognized that a cut of this magnitude would likely result in the closing of many HBO2 facilities across the US, depriving patients of necessary medical services and potentially closing many 24/7 facilities, further exacerbating the shortage of such facilities. Time was critical as this OPPS Final Rule was set to go into effect in just seven weeks.
We suspected this drastic change between the Proposed and Final Rule of the OPPS was due to a clerical error in data entry. UHMS immediately notified CMS, asking them to please review their data. We also engaged our membership in a letter-writing campaign, met regularly with our corporate stakeholders (Alliance of Wound Care Stakeholders), and engaged Dobson Davanzo & Associates LLC, a healthcare economic and policy consulting firm with expertise in CMS data sets.
Dobson Davanzo’s analysis concluded this was an error, and their final report was submitted to CMS via the Alliance of Wound Care Stakeholders on Dec 8, 2023. On Dec 21, 2023, CMS acknowledged this error and corrected the G0277 reimbursement rate to $132.21, a 5.4% increase from 2023. Crisis averted.
I want to thank Dr. Helen Gelly, John Peters, the representatives from the Alliance of Wound Care Stakeholders, Dobson Davanzo, UHMS Corporate Partners, and all of the UHMS members who supported this effort through letter writing, phone calls to political representatives, etc.
I am very proud of our specialty for coming together on short notice during a crisis.
I hope to see you all in New Orleans for the UHMS Annual Scientific Meeting in June.