The Centers for Medicare and Medicaid Services (“CMS”) issued a proposed rule that would update payment policies for the Medicare Physician Fee Schedule (“PFS”). These policy charges are intended to reduce paperwork burdens, remove “unnecessary measures” and “recogniz[e] clinicians for the time they spend with patients.” If finalized, the rule would take effect for Medicare services provided on or after January 1, 2020.
The proposed rule contains a number of provisions relating to Medicare payments, as follows:
Comment Solicitation on Opportunities for Bundled Payments under the PFS: Seeks comments on expanding bundling to improve payment under the PFS and to align PFS payment with the broad CMS policy of improving accountability and efficiency.
CY2020 PFS Rate Setting and Conversion Factor: Includes a series of technical proposals involving practice expense, including implementing the second year of the market-based supply update, as well as rate setting adjustments related to malpractice expense and geographic practice cost indices.
Medicare Telehealth Services: Adds codes for telehealth services related to care for opioid use disorders.
Payment for Evaluation and Management (“E/M”) Services: Includes Current Procedural Technology (“CPT”) coding changes to allow refinements in the coding for E/M visits, and to reduce administrative burdens.
Bundled Payments under the PFS for Substance Use Disorders: Includes new coding and payment for a bundled episode of care for management and consulting of these disorders.
Care Management Services: Increases payment for Transitional Care Management.
Therapy Services: Establishes modifiers for services provided in whole or in part by physical therapy and occupational therapy assistants.
There rule also contains several other provisions:
Physician Supervision Requirements for Physician Assistants (“PAs”): Proposes allowing PAs to practice more broadly.
Review and Verification of Medical Record Documentation: Modifies the record documentation policy to permit review and verification, which is relatively less time-intensive than the current re-documenting of medical record notes made by prior providers.
Medicare Coverage for Opioid Use Disorder Treatments Furnished by Opioid Treatment Programs (“OTPs”): Includes provisions relating to defining treatment services, enrollment policies, and bundled payment rates.
Ambulance Services: Clarifies procedure for physician certification statements for ambulance transports.
Ground Ambulance Data Collection System: Provides for a data collection system to collect “cost, revenue, utilization and other information” for ground ambulance providers.
Open Payments Program: Modifies the Open Payments program with respect to the definition of “covered recipient,” as well as altering payment categories and standardizing data reporting.
Medicare Shared Savings Program: Solicits comments on aligning the quality performance scoring methodology with the methodology used in other programs.
Stark Advisory Opinion Process: Solicits comments on potential changes to the Advisory Opinion process.
CMS Administrator Seema Verma noted that the proposed changes are intended to give physicians the “support they need to spend valuable time coordinating the care of these patients to ensure their diseases are well-managed and their quality of life is preserved.” Comments are being accepted until September 27, 2019.