When the Centers for Medicare and Medicaid Services (CMS) recently released the final rule of the Medicare Physician Fee Schedule (MPFS), this was the first year in a while that industry insiders weren’t scouring for guidelines related to the Physician Quality Reporting System or the Value-Based Payment Modifier. With those programs being replaced through the MACRA Quality Payment Program, the MPFS dealt primarily with payment policies.
2017 Conversion Factor
The 2017 PFS conversion factor is $35.89, a slight increase to the 2016 PFS conversion factor of $35.80. While increases to the 2017 fee schedule were set at .5 percent under MACRA, in another law, the Achieving a Better Life Experience (ABLE) Act of 2014, Congress mandated adjustments to misvalued codes (1 percent in 2016 and .5 percent in 2017 and 2018) in the fee schedule. If the mandated adjustments fell short of the targets, then the difference would be pulled from the .5 percent MACRA increase.
Since savings through misvalued codes was estimated at only .32 percent, that adjustment, plus other mandated adjustments, was made to the conversion factor, resulting in an approximate .25 percent increase.
Primary Care and Patient-Centered Care Management
Also in the 2017 MPFS, CMS continues to work toward better payment guidelines for primary care and patient-centered care management. For instance, Medicare will now make separate payments for certain non-face-to-face prolonged evaluation and management services, as well as revalue the CPT codes for other face-to-face prolonged services. The final rule also allowed for payment of comprehensive assessment and care planning for patients with cognitive impairment, or dementia, along with interprofessional care management resources used to treat patients with behavioral health conditions. Finally, the 2017 MPFS allows for payment of chronic care management for patients with greater complexity, while at the same time reducing the administrative burden associated with the chronic care management.
CMS also finalized its proposed modifications to revalue several procedure codes to remove the work RVUs associated with moderate sedation. The work RVUs for GI endoscopy procedures will be reduced by .10, and all other services by .25 from current values.
Gastroenterology procedures were treated differently, according to CMS, because “gastroenterologists furnish the highest volume of services previously identified in Appendix G, and services primarily furnished by gastroenterologists prompted the concerns that led to our identification of changes in medical practice and potentially duplicative payment for these codes.”
Practitioners furnishing the moderate sedation services (often anesthesiologists) will have no change in their overall work RVUs.
Post-Surgical Data Collection
Another provision of MACRA required CMS to gather data on evaluation and management services in the post-surgical (or global) period in order to correctly value these surgical services. The administrative burdens on physicians to report data, however, was significant, and CMS sought to reduce that burden by finalizing the following guidelines in the 2017 MPFS:
- Require post-operative visits for high-volume/high-cost procedures only.
- Use existing CPT code 99024 instead of the proposed G-codes.
- Require reporting from only a sample of practitioners (based on state and practice size)
- Allow all others to report voluntarily.
- Limit reporting requirements to services furnished after July 1, 2017.
In addition, while practitioners are encouraged to begin reporting post-operative visits for procedures furnished on or after January 1, 2017, the requirement to report will be effective for services related to global procedures furnished on or after July 1, 2017. To the extent that these data result in proposals to revalue any global packages, that revaluation will be done through notice and comment rulemaking at a future time.
Finally, CMS took the opportunity of the 2017 MPFS to create consistency among the various health care provider and supplier enrollment requirements for Medicare Part A, Part B, and Part D programs.
Basically, health care providers or suppliers who fail to meet CMS enrollment requirements or violates certain federal rules and regulations for one program may have have their provider or supplier’s enrollment revoked from the other programs. The new guideline also prevents Medicare Advantage plans from making payments to individuals or entities that have been excluded by the Office of Inspector General or have been revoked by the Medicare program, regardless of if that provider or supplier is out of network.
For more information about the 2017 MPFS, review the CMS Fact Sheet, “Final Policy, Payment, and Quality Provisions in the Medicare Physician Fee Schedule for Calendar Year (CY) 2017,” or scan through the 393-page final rule located on the federalregister.gov.
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