CMS Starts Phase-out of Inpatient-Only Procedures (IPO) List
The CMS 2021 HOPPS final rule begins the three-year phasing out of the Medicare Inpatient-Only (IPO) List, which designates procedures and services that can only be reimbursed in an inpatient hospital setting. Procedures removed from the IPO list will now be eligible for outpatient payment when outpatient care is deemed appropriate for the case. For 2021, 298 procedures were removed from the IPO List, the majority of which are musculoskeletal in nature.
These procedures will be exempt from site-of-service claim denials until enough claims data is collected. This is to determine if the procedures are performed more frequently in outpatient settings than inpatient settings, taking into account the two-midnight rule. By January 2024, the full list will be eliminated.
Since the list was developed in 2000, CMS has expressed the expectation of the surgeon and facility assessing the patient’s risk and acting in the patient’s best interest, including the site of service. It is believed this clinical judgement, as well as state and local regulations, accreditation requirements, medical malpractice laws, hospital conditions of participation and other CMS quality initiatives will continue to ensure the patient’s best interest without the IPO list.
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