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Medicare 2015 Physician Fee Schedule Final Rule released

The 2015 Medicare Physician Fee Schedule (MPFS) Final Rule with Comment Period (CMS-1612-FC) was released late last week. This major final rule revises payment polices under the Medicare Physician Fee Schedule (PFS) and makes other policy changes related to Medicare Part B reimbursement. These changes are applicable to services furnished in 2015. The Social Security Act (the Act) requires the Centers for Medicare and Medicaid Services (CMS) to establish payments under the PFS based on national uniform relative value units (RVUs) that account for the relative resources used in furnishing a service. In addition to establishing RVUs for new, revised and misvalued codes for 2015, this rule includes discussions and proposals regarding:

  • 2015 MPFS Conversion Factor: The 2015 MPFS conversion factor is $35.8013 for Jan. 1, 2015 through March 31, 2015, due to Congress passing a “patch” to the Sustainable Growth Rate (SGR) in April of this year. The “patch” provided for a zero percent update for services furnished between Jan. 1, 2014 and March 31, 2015. If Congress does not intervene before April 1, 2015, the MPFS 2015 conversion factor for April 1, 2015 through Dec. 31, 2015 will be $28.2239. This means that physicians would face a 21.2 percent reduction in reimbursement for Medicare Part B services. The Wisconsin Medical Society continues to advocate for a full repeal and replacement of the SGR.
  • Chronic Care Management: Medicare primarily bundles care management services provided by physicians and other qualified health care professionals into other face-to-face visits. Beginning in 2015, CMS will reimburse for chronic care management (CCM) services separately for Medicare beneficiaries who have two or more significant chronic conditions. The final rule establishes a payment rate for CCM services that may be billed up to once per month for each qualified patient. CCM services include communication and coordination among a care team, medication management and reconciliation and consistent review of a comprehensive care plan. Both CMS and CPT guidelines will apply to these services in 2015.
  • Value-Based Payment Modifier: CMS finalized application of the Value-Based Payment Modifier (VBPM) beginning in calendar year (CY) 2017 to all physicians, including physicians in groups with two or more eligible professionals (EPs) and physicians who are solo practitioners. This will be based on required information reported in 2015. CMS estimates that this will affect an additional 900,000 physicians. CMS also finalized application of the VBPM to non-physician EPs in groups with two or more EPs and to non-physician EPs who are solo practitioners beginning in CY 2018. Maximum penalties depend on group size and participation.
  • Physician Quality Reporting System (PQRS): CMS will continue implementing quality improvement initiatives for physicians via the PQRS; 2015 PQRS reporting for individual measures is unchanged from the 2014 reporting year. To avoid a 2 percent PQRS penalty (applied in 2017), CMS is requiring that EPs report nine measures, covering three of the National Quality Domains for at least 50 percent of an EP’s Medicare Part B fee-for-service (FFS) patients seen during 2015. However, there are no incentives for successful reporting PQRS in 2015. The final rule establishes new requirements related to the PQRS payment adjustment for 2017.
  • Physician Compare: CMS is expanding public reporting via the Physician Compare website. Group level measures will be expanded to make all 2015 PQRS Group Practice Reporting Option (GPRO) web interface, registry and electronic health record (EHR) measures for group practices of two or more EPs and Accountable Care Organizations available for public reporting on Physician Compare in 2016. In addition, all 2015 PQRS individual measures collected via registry, EHR or claims will be made available for public reporting on Physician Compare in late 2016 if technically feasible.
  • Telehealth Services: CMS has once again expanded the list of telehealth services available to Medicare beneficiaries to include annual wellness visits, psychotherapy, prolonged evaluation and management services and more.
  • Global Surgery: The Health and Human Services Office of Inspector General has identified a number of surgical procedures that include more visits in the global period than are being furnished. CMS also is concerned that postsurgical visits are valued higher than visits that were furnished and billed separately by other physicians, such as general internists or family physicians. CMS proposed to transform all 10- and 90-day global codes to zero-day global codes beginning in CY 2017. After consideration of all the comments, CMS finalized the proposal beginning with 10-day global services in CY 2017 and following with the 90-day global services in 2018.

The Society’s upcoming three-hour seminar, 2015 Forecast: Medicare, Legislation and More will address several of these points. To learn more or register online for the event, which is Dec. 3 at Summit Place in West Allis and Dec. 4 at the Tundra Lodge Resort in Green Bay, visit the Society’s Continuing Education Center.

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