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Society submits comments on proposed Medicare Physician Fee Schedule rule

The Wisconsin Medical Society submitted extensive comments earlier this week to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed 2016 Medicare Physician Fee Schedule (PFS). The proposed rule includes updates in policies related to advance care planning, the physician Value-Based Payment Modifier (VBPM), implementation of the Merit-Based Incentive Payment System (MIPS) and Appropriate Use Criteria (AUC).

Included in the proposed rule is CMS’s intent to reimburse for advance care planning codes for the first time.

“The Society appreciates CMS’s decision to fund CPT codes 99497 and 99498 in the proposed rule for the 2016 PFS. This is an important step forward for better advance care planning; we strongly support the codes and the reimbursement for ACP conversations under these codes,” said the Society’s John Maycroft, on behalf of Honoring Choices Wisconsin—an initiative of the Society.

In addition to commenting on advance care planning, the Society also commented at length on the VBPM, the MIPS and AUC. Highlights include:

  • The Society sees CMS’s implementation of the physician VBPM as positive and consistent with creating a program that will better reward high-quality care for patients at a lower cost for the payer.
  • The Society appreciates that CMS continues to work to harmonize Meaningful Use (MU), the Physician Quality Reporting System (PQRS) and VBPM quality reporting programs, but believes there is still a long and difficult road ahead as CMS’s new PQRS reporting mechanisms—Qualified Clinical Data Registries (QCDR)—could, if not done right, drive us further away from MU clinical quality measure reporting.
  • The Society believes that the practice of medicine and specialty societies should be the default group to offer AUC.

To read the comments in their entirety, click here.

Society staff members Chris Rasch and Jen Cohrs will help physicians and their staffs understand the changes in the proposed rule during their Highlights of the 2016 Medicare Physician Fee Schedule Proposed Rule presentation at the Society’s Symposium 2015 on Sept. 22. To learn more about this event and to register, click here.

CMS is expected to release the final rule in November. More information about the 2016 Medicare Physician Fee Schedule proposed rule is available in this CMS fact sheet.

The name “Honoring Choices Wisconsin” is used under license from Twin Cities Medical Society Foundation.

Back to September 10, 2015 Medigram