Thursday, July 10, 2014

Proposed Policy and Payment Changes to the Medicare Physician Fee Schedule for CY 2015

On July 3, CMS issued a proposed rule that would update payment policies and payment rates for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2015. CMS is proposing a new process for establishing PFS payment rates that will be more transparent and allow for greater public input prior to payment rates being set. Under the new process, payment changes will go through notice and comment rulemaking before being adopted beginning for 2016.
Sustainable Growth Rate (SGR)
The proposed rule does not include proposals or announcements on the PFS update or SGR as these calculations are determined under a prescribed statutory formula that cannot be changed by CMS. The final figures are announced in the final rule in November. The Protecting Access to Medicare Act (PAMA) of 2014 provides for a zero percent PFS update for services furnished between January 1, 2015 and March 31, 2015. In March (prior to the enactment of the PAMA), CMS estimated that the PFS update for CY 2015 would be -20.9 percent. In most prior years, Congress has taken action to avert a large reduction in PFS rates before it went into effect. The Administration supports legislation to permanently change SGR to provide more stability for Medicare beneficiaries and providers while promoting efficient, high quality care.
Provisions in the CY 2015 PFS proposed rule that may be of interest to AHCA members include:
 Primary care and complex chronic care management 
  • Misvalued codes (including several codes commonly used for billing Part B therapy services)
  • Enhanced transparency in rate setting
  • Telehealth services
  • Adjustments to malpractice Relative Value Units (RVUs)
  • Revisions to Geographic Practice Cost Indices (GPCIs)
 CMS will accept comments on the proposed rule until September 2, 2014. For more information:
· Fact Sheet: Proposed Policy and Payment Changes to the Medicare PFS for CY 2015
· Fact Sheet: Changes for CY 2015 Physician Quality Programs and Other Programs in the Medicare PFS
· Fact Sheet: Proposed Changes for the Physician Value-based Payment Modifier in the CY 2015 Medicare PFS Proposed Rule
· Open Payments website
Members that have questions about the proposed rule or have suggestions for AHCA to consider as we prepare our comments may submit them to Dan Ciolek.      

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