On July 8, 2013, CMS released the annual Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule for calendar year 2014 (the “Proposed Rule”).  Significant proposed changes include the establishment of comprehensive APCs for high-cost device-dependent services, increased packaging of drugs and ancillary services, and the elimination of 5 coding levels for outpatient clinic and ED visits.  Comments are due by September 6, 2013.