Wednesday, January 7, 2015

CMS Corrects Updates to 2015 Medicare Part B Physician Fee Schedule File – Updated Therapy File Posted on AHCA Website

Dan Ciolek

Last week the Centers for Medicare and Medicaid Services (CMS) announced that they would hold CY 2015 Part B claims for 14 business days to correct technical errors identified in the November 13, 2014 fee schedule rule. See related article (here). CMS also furnished an updated fee schedule file. Thanks to the efforts of Tony Marshall, the Senior Director of Reimbursement for the Florida Health Care Association, AHCA is able to post the updated 2015 Medicare Part B Fee Schedule that applies to Part B therapy services for the period from January 1 through March 31, 2015 here.

Included in this file are tables related to Part B therapy services, including the continuation of the multiple procedure payment reduction (MPPR) policy.

The following provides additional background and guidance regarding how to read and use the updated file:

The updated 2015 (January through March) therapy fees for each CPT/HCPCS Code in each geographic area are provided in the attached Excel spreadsheet. This document has four worksheets containing the following information:

1. The 2015 Medicare Part B Fee Schedule (Part B Fees) for Outpatient Rehabilitation for each Carrier and Locality.

2. The 2015 Medicare Part B MPPR Fee Schedule (MPPR) for “Always Therapy” Services (50% MPPR Factor).

3. The 2015 Relative Value Units (RVUs) for each Outpatient Rehabilitation Therapy Code.

4. The 2015 Geographic Practice Cost Indices (GPCI) by Medicare Carrier and Locality.

The final Part B Fee Schedule amounts are calculated as follows:

(( A1 x B1) + (A2 x B2) + (A3 x B3)) x Conversion Factor (Part B Fees), and

(( A1 x B1) + ((A2 x B2) x (1-MPPR Factor)) + (A3 x B3)) x Conversion Factor (MPPR Part B Fees), where:

A1 = Physician Work RVU
A2 = Non-Facility Practice Expense RVU
A3 = Malpractice RVU
B1 = Work GPCI
B2 = Practice Expense GPCI
B3 = Malpractice GPCI

Conversion Factor = $35.7547 (Updated)

MPPR Factor = 50%

Please note that the updated fees reflect all changes included in the CY 2015 Medicare Physician Fee Schedule Final Rule published in the Federal Register on November 13, 2014 and reflects implemented corrections to technical errors discovered after publication of the MPFS rule. The fee schedule also reflects legislation (Section 101 of the Pathway for SGR Reform Act of 2013 and Sections 101 and 102 of the Protecting Access to Medicare Act of 2014) which provided for a one-half percent (0.5%) update to the Medicare Physician Fee Schedule effective January 1, 2014, a zero percent (0.0%) update for services provided January 1, 2015 through March 31, 2015, and extended the 1.0 Work GPCI floor through March 31, 2015. After March 31, 2015, the standard calculation of the Medicare Physician Fee Schedule under the SGR formula will apply which is expected to result in a reduction to payment rates of 21.2 percent for the remainder of CY 2015. (CMS notes in the Final Rule that they will continue to work with Congress to develop a long-term solution to fix this untenable situation.)

The outpatient therapy beneficiary cap for CY 2015 is $1,940 for physical therapy and speech-language pathology combined, and $1,940 for occupational therapy. Section 103 of the Protecting Access to Medicare Act of 2014 extended the therapy caps exceptions process through March 31, 2015. The current MMR policies and procedures remain in effect until March 31, 2015 pending further legislation.

The final rule also continues the multiple procedure payment reduction (MPPR) policy for “always therapy” services. The MPPR policy required, effective April 1, 2013, a 50 percent reduction to be applied to the practice expense component of payment for the second and subsequent “always therapy” service(s) that are furnished to a single patient by a single provider on one date of service (including services furnished in different sessions or in different therapy disciplines). The MPPR worksheet lists those “always therapy” services subject to the MPPR policy and the reduced fee payment amounts.

An overview of the Physician Fee Schedule Payment Policies may be found on the CMS website and an overview of skilled nursing facility consolidated billing and annual updates can be found here. Additional state-specific details for 2015 can be found online.

Additional schedules will be provided before the April 1, 2015 rate changes and/or following further legislation.

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