Thursday, June 11, 2015

CMS Updates 2015 Medicare Part B Physician Fee Schedule File for Services Furnished July-December 2015 – Updated Therapy File Posted on AHCA Website

Dan Ciolek


The recently enacted Medicare Access and CHIP Reauthorization Act of 2015 included provisions that allowed the zero percent update that would have ended on March 31, 2015, to continue through to June 30, 2015, and allows for a one-half percent (0.5%) update from July 1, 2015, to December 31, 2015. 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 July 1 through December 31, 2015.

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

2. The July 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 = $35.9335

MPPR Factor = 50%

Please note that the 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 subsequent implemented corrections to technical errors discovered after publication of the MPFS rule. The Medicare Access and CHIP Reauthorization Act of 2015 allowed the zero percent update that would have ended on March 31, 2015, to continue through to June 30, 2015, and allows for a one-half percent (0.5%) update from July 1, 2015, to December 31, 2015. It also extends the physician work geographic practice cost index (GPCI) floor of 1.0, and the therapy cap exceptions process, through December 2017.

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 202 of the Medicare and CHIP Reauthorization Act (MACRA) of 2015 extended the therapy caps exceptions process through December 31, 2017. The MACRA Act also required reforms of the therapy manual medical review (MMR) policies and procedures within 90 days of enactment, which we anticipate occurring on or about July 15, 2015. We are awaiting further details on the MMR changes to be implemented.

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.

The May 15, 2015, MLN Matters Article (MM 9152) can be found at http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9152.pdf and the Related Change Request (Transmittal 3259; CR 9152) can be found at http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3259CP.pdf. An overview of the Physician Fee Schedule Payment Policies may be found at http://www.cms.hhs.gov/PhysicianFeeSched/ and an overview of skilled nursing facility consolidated billing and annual updates can be found at http://www.cms.gov/Medicare/Billing/SNFConsolidatedBilling/. Additional state-specific details for 2015 can also be found online.

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