November 13, 2014
Area(s) of Interest: Payor Contracting Payor Issues and Reimbursement Public Payors
The Centers for Medicare and Medicaid Services (CMS) published its 2015 Medicare Physician Fee Schedule final rule Thursday in the Federal Register. The 1,200 word payment rule contains several notable changes.
As earlier proposed, the rule expands the services eligible for telemedicine reimbursement and extends the new payment policies for non-face-to-face care coordination. It allows primary care physicians to be paid for care management of Medicare beneficiaries with two or more chronic conditions. These are tasks (including managing lab and imaging reports, medications and care plans in addition to talking with patients and families on the phone) physicians commonly provide, but have not been paid for in the past.
Although CMS continues to move up the implementation timeline for the Value-Based Payment Modifier (VBM), the final rule scales back the penalties for practices with fewer than 10 physicians as urged by the California Medical Association (CMA) and the American Medical Association (AMA). While the final rule still maintains a potential pay cut of 4 percent for larger medical groups, practices with fewer than 10 physicians will not be subject to more than a 2 percent VBM penalty. AMA and CMA have called for a slower phase-in of the VBM. CMA is supporting the VBM program reforms in the Medicare sustainable growth rate (SGR) overhaul legislation (HR 4015/S 2000). CMA also continues to fight the inappropriate implementation of the value modifier that discriminates against physicians caring for frail, elderly patients.
Also removed from the final rule was CMS's earlier proposal to eliminate the CME exemption in the Physician Payments Sunshine Act, which requires reporting and public posting of financial interactions between medical device and drug manufacturers and physicians and teaching hospitals. CMA and AMA joined dozens of other medical associations in calling on the agency to eliminate this requirement because it would “chill physician participation in independent [continuing education] programs.”
CMS is moving forward with the public disclosure of physician quality and meaningful use information on the Physician Compare Website. However, at CMA’s and AMA’s urging, physicians will be allowed to review the information and correct inaccurate data prior to publication. CMS also pulled back its proposal to publish benchmark information.
CMS is also proceeding with the plan to require physicians to report nine quality measures in three “domains” and one “cross-cutting” measure in 2015 for the Physician Quality Reporting System (PQRS).
And in 2015, the Physician Quality Reporting System (PQRS) becomes a penalty-only program. No bonuses will be paid. Physicians must successfully report in 2015 to avoid penalties in 2017.
The final rule includes 350 CPT codes identified as new, revised or potentially misvalued—318 of these changes were based on physician input. These changes represent 86 percent of those recommended by the AMA/Specialty Society Relative Value Scale Update Committee, an expert panel of more than 300 participants that includes physician advisers from every medical specialty. The panel develops and provides relative value recommendations annually to CMS.
Despite strong opposition from AMA, CMA and others in organized medicine, CMS moved forward with the elimination of all 10- and 90-day global surgical packages because CMS says it lacks the ability to verify the number, type and relative costs of postoperative visits. Packages would only include preoperative services and care given the day of surgery. CMS will be transitioning all services with a 10-day global period to a 0-day global period by 2017. All 90-day global periods will be shifted to 0-day global periods by 2018.
CMA continues to urge Congress to pass the bipartisan, bicameral SGR repeal and Medicare physician payment reform legislation (HR 4015/S 2000), which would provide bonuses to physicians for meeting the Medicare PQRS and value modifier standards and overhaul the Medicare payment framework.
For more information about these and other components of the 2015 Medicare Physician Payment Rule, see the AMA summary or the CMS fact sheets.