A GYN procedure was initially placed in Group 4 under the old ASC payment system. In addition, the company launched the first generation device with an ASP that was insufficient once the product was redesigned. The low reimbursement made performing the procedure a non-starter in the ASC as the reimbursement was less than the cost of the device.

The JD LYMON Solution: We prepared a case for Ambulatory Surgery Center (ASC ) payment reassignment, met with the Centers for Medicare and Medicaid Services (CMS) staff and submitted an application for a HCPCS code. In addition, comments were provided to the Proposed Rules, requesting three fixes:

1. A new ASC payment assignment
2. A HCPCS device code for separate device payment
3. An increase in the direct practice expense RVUs for physician office payment

Results: Over the course of three years, all three fixes were achieved, resulting in the procedure being economically viable in all settings of care.