Proposed Rule CY 2015 Medicare Part B
The Centers for Medicare and Medicaid Services (CMS) has released the proposed rule for the calendar year (CY) 2015 Medicare Physician Fee Schedule (MPFS), which includes Medicare Part B rates and policies for ancillary services provided by nursing homes and home health agencies. The rule in its entirety is available by clicking here. In addition, a fact sheet issued by CMS is available by clicking here. A separate CMS fact sheet on the quality initiatives in the proposed rule is available by clicking here.
Under the proposed rule the payment and policies updates would be effective Jan. 1, 2015. The comment period ends Sept. 2, 2014 at 5:00 p.m. Submissions should reference file code CMS-1612-P and may be sent electronically to www.regulations.gov. Once at this website users will be prompted as to additional instructions. Please see the proposed rule for instructions on submitting by regular mail.
Highlights of the proposed rule include:
Non Face-to-Face Payments: The CY 2014 final rule authorized a payment mechanism for service not related to a face-to-face visits effective Jan. 1, 2015. The CY 2015 proposed rule seeks to establish the details for how such a payment mechanism would work (see Chronic Care Management below).
Transparency in Payment Policies: CMS is proposing a process that would increase transparency in the development of payment polices to take effect in 2016.
Quality Reporting Initiatives: Proposed changes in this area would impact the Physician Quality Reporting System (PQRS), Medicare Shared Savings Program, and Medicare Electronic Health Record (EHR) Incentive Program, as well as changes to the Physician Compare tool on the Medicare.gov website.
Physician Value-Based Purchasing: The proposed rule continues the phase in of the physician value-based payment modifier as mandated under the Affordable Care Act tying traditional physician and other professionals Medicare fee-for-service payments to certain quality and cost measures.
Sustainable Growth Formula (SGR): For several years now, the fact that annual payment adjustments have been tied to the SGR formula has created the unfortunate circumstance of projecting ever increasing negative rate adjustments that require Congress to act to override. This current proposal does not include the impact of the SGR on CY 2015 rates. Since the application of the SGR formula is mandated under statute, CMS does not announce the final rates until Nov. However, we can predict from recent trends that once again the SGR will mandate a significant reduction in rates, which Congress will need to override. Due to special legislation passed by Congress this year, current rates are protected through March 31, 2015. However, for the remainder of 2015 the SGR will likely call for a negative rate adjustment in excess of 20 percent. Again, Congress has always acted to avert these large negative adjustments as CMS continues to struggles with developing an alternative to the SGR. For budgeting purposes I would assume Medicare Part B 2015 payment rates level with 2014.
Primary Care and Chronic Care Management (CCM): As part of its initiative to promote primary care services, CMS is proposing a policy to implement separate payment for non-face-to-face chronic care management services for Medicare beneficiaries with multiple chronic conditions, including care planning, coordination of services and medication management. The rule does not include separate CCM standards as CMS believes the methodology established last year is sufficient for CCM purposes. CMS is, however, looking for stakeholder input on whether additional standards are needed specifically to deal with electronic health records under CCM.
Misvalued Codes: CMS continues its efforts to identify and correct potentially misvalued codes, both through their own internal algorithms and based on public input. In the case of radiation therapy services, they are seeking a reduction in payments that would be redistributed to other MPFS services. They are also seeking to update the practice expense units associated with new digital x-ray technology replacing analog film.
Global Surgery: The proposed rules seeks to split the global surgery code between services provided on the day of surgery and those provided post-surgery beginning is 2017.
Telehealth Services: CMS is proposing to add the following to the list of services that can be reimbursed under the telehealth benefit: annual wellness visits, psychoanalysis, psychotherapy, and prolonged evaluation and management services.
Adjustments to Malpractice RVUs: CY 2015 represents the third consecutive review and update of the malpractice relative value units, based on updated professional liability insurance premiums.
Revisions to Geographic Practice Cost Indices (GPCIs): The proposed GPCIs reflect the elimination of the 1.0 work GPCI floor from April 1, 2015 through December 31, 2015.
Off-Campus Provider-Based Departments: CMS is proposing a new modifier to report services furnished in off-campus provider-based departments on both hospital and physician claims in order to collect data on such services to be used to further evaluate the payment policies in this area.
Open Payments: Open Payments is a national disclosure program that publishes information about these financial relationships between drug and device manufacturers and certain health care providers on a publicly accessible website developed by CMS. It also requires certain manufacturers and group purchasing organizations (GPOs) to report ownership, interests, or payments involving physicians or their immediate family members. Under the proposed rule, CMS is recommending several changes to the program.
Contact: Patrick Cucinelli, pcucinelli@leadingageny.org, 518-867-8827