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CMS Releases FY2014 Physician Fee Schedule and Hospital Outpatient Proposed Payment Rules

Posted on 7/9/2013 by NTOCC ®

Yesterday, the Centers for Medicare & Medicaid Services (CMS) issued two proposed rules that would update payment policies and rates for services furnished under the Medicare Physician Fee Schedule (PFS) and address payment and policy changes for the hospital outpatient prospective payment system (OPPS) and the ambulatory surgical center (ASC) payment system. The rule also proposes changes to several of the quality reporting initiatives that are associated with PFS payments – the Physician Quality Reporting System (PQRS) and the Medicare Electronic Health Record (EHR) Incentive program. In addition, the rule continues the phased-in implementation of the physician value-based payment modifier, created by the Affordable Care Act, which would affect payments to physician groups based on the quality and cost of care they furnish to beneficiaries enrolled in the traditional Medicare fee-for-service program. Among other changes, CMS proposed bundling seven new categories of supporting items and services in payments for primary care, and combining five levels of outpatient visit codes into a single Healthcare Common Procedure Coding System (HCPCS) code for each type of outpatient visit.

Of particular interest to NTOCC, the proposed PFS rule would complement last year’s finalization of a separate payment for transitional care management services for beneficiaries transitioning from a hospital to their community-based primary care physician by proposing to add another separate payment for complex chronic care management services, beginning in 2015.  According to CMS, this change is aimed at bolstering primary care services, as the Agency has heard from the physician community that the care management included in the Evaluation and Management (E/M) service codes for many complex chronic care patients is not adequate in capturing the typical non-face-to-face care management work involved for these beneficiaries.  Under the CMS proposal, payments would be made for the development and revision of care plans, and could include monitoring of patients’ medical and functional needs, subject to the patient having an annual, in-person wellness visit.

CMS has also proposed to add the transitional care management service codes finalized last year to the list of Medicare telehealth services for FY2014 on a category 1 basis.

While CMS has proposed adding five new measures for the outpatient quality reporting (OQR) program starting in 2016, in exchange, the Agency has proposed removing two chart-abstracted measures from the OQR, including the removal of “OP-19: Transition Record with certain Elements Received by Discharge ED Patients.” CMS sited that the measure has been suspended since 2012, in response to hospitals raising concerns about potential privacy issues related to releasing certain elements of the transition record to either the patient being discharged from an emergency department or the patient’s caregiver. CMS determined that the measure could not be implemented with the degree of specificity that would be needed to fully address the concerns of stakeholders without being overly burdensome. However, CMS noted that all aspects for this transition record measure are currently required to meet the Medicare EHR Incentive Program’s meaningful use (MU) core objective to provide patients the ability to view online, download, and transmit information about a hospital admission.

CMS will accept comments on the proposed rule until September 6, 2013 and will respond to them in a final rule with comment period to be issued around Nov. 1, 2013.  To view the proposed physician fee schedule rule, please click here.  To view the proposed hospital outpatient and ambulatory surgical center (ASC) payment system rule, please click here.

NTOCC staff will continue to examine the details of the proposed rule and will be discussing the development of comments with the Policy & Advocacy working group.