On April 25, 2016, the Centers for Medicare and Medicaid Services (CMS), published the annual proposed rule that will govern Medicare coverage of Skilled Nursing Facility (SNF) services through its established Prospective Payment System (PPS). Included in the proposed rule is an opportunity for the public to suggest additions to the list of HCPCS codes that are exempt from the SNF PPS system and therefore, payable by the DME MACs as Medicare Part B services. While most prosthetic services are currently exempt from SNF PPS, there are several codes that have been historically not included in the PPS exempt list and therefore must still be billed to the SNF directly. These include HCPCS codes that describe partial hands and feet as well as L5987 which describes a “shank foot system with vertical loading pylon.” As it has done in the past, AOPA will provide formal comments requesting the inclusion of these codes in the SNF PPS exempt list. AOPA believes that these codes meet the regulatory requirement for SNF PPS exclusion (low volume and high cost) and should be added to the list of HCPCS codes that are exempt from SNF PPS.
Comments on the SNF PPS proposed rule will be accepted until 5 PM EDT on June 20, 2016. Instructions on how to submit comments are included in the proposed rule. Questions regarding this issue may be directed to Joe McTernan at firstname.lastname@example.org or Devon Bernard at email@example.com.