On October 31, the Centers for Medicare & Medicaid Services (CMS) released the Final Rule for the 2015 Medicare Physician Fee Schedule (PFS). The 1,185-page document didn’t feature any significant departures from the Proposed Rule released by CMS in July, but the details are important to review to ensure a solid knowledge base of what’s to come in 2015 as it relates to your reimbursement. With Medicare being the bellwether for our industry, here are the highlights of the CMS decree.
The current Medicare PFS will remain intact until March 31, 2015, thus avoiding the annual holiday panic about plunging payments. On April 1, 2015, however, CMS confirmed that reimbursement will drop 21.2% unless the federal government steps in to reverse it.
Chronic care management services will be paid as of the January 1, 2015 date of service. Instead of creating a new G code, as proposed, the government will use the already established CPT® code, 99490. 99490, which will pay approximately $40, can be billed for non-face-to-face services related to managing the care of a Medicare patient with two or more chronic conditions. CMS dropped its requirement for the practice to have a 2014-certified electronic health record (EHR) system, choosing instead to mandate the version of the certified EHR that is in use on December 31 of the prior calendar year.
Significant cuts to particular specialties, such as radiation oncology, based on RVU changes were reversed; the only physician specialties with an estimated negative impact of more than one percent were dermatology and ophthalmology. For those specialties, the estimated impact of changes to RVUs is a negative two percent.
Medicare beneficiaries no longer have to pay for anesthesia provided separately during a screening colonoscopy. As of January 1, 2015, the deductible and coinsurance will both be waived as CMS is including separately provided anesthesia as part of the definition of the screening service.
Physicians and other eligible professionals must report on nine measures in 2015 for the Physician Quality Reporting System (PQRS). Successful reporting can avoid the two percent penalty, which will be imposed in 2017 based on 2015 participation.
The Value-Based Payment Modifier (VBPM) is being rolled out without delay. To avoid payment adjustments, 2015 reporting is required for all physicians, regardless of practice size. The government increased the penalty to four percent for practices with 10 or more eligible professionals, noting that the definition of an EP is quite broad.
The global period for surgery codes – 10- and 90-days – is on the chopping block, with confirmation that CMS will begin the phase-out of this coding convention in 2017. The global periods will be replaced by 0-day global codes, thus migrating all surgeries and procedures into per-service coding.
CMS packed in more information to the Final Rule; look for your specialty society to release an assessment of the regulation’s impact on your practice soon. The document will be on display for the next few days, until it is published in its final form in the Federal Register on November 13, 2014.