Unwrapping the OPPS Packaging: Facility Reimbursement of SaaS Procedures
This Bulletin is brought to you by AHLA’s Regulation, Accreditation, and Payment Practice Group.
- December 20, 2022
- Katie Sullivan , Kirkland & Ellis LLP
Advances in artificial intelligence and computer-aided detection (CAD) have enabled the development of advanced clinical decision support tools to assist in the diagnosis or treatment of patient conditions. Contrary to broader industry usage, the Centers for Medicare & Medicaid Services (CMS) narrowly defines “software as a service” (SaaS) as “algorithm-driven services that assist practitioners in making clinical assessments, and that provider pay for either on a subscription or per-use basis.” However, many SaaS procedures require the simultaneous performance of diagnostic imaging services that are already reimbursed by CMS. Under CMS rules, such services would generally be packaged into reimbursement for the imaging service, which has the potential to chill development of additional SaaS procedures.
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