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Insights

Jul 09, 2014

CY 2015 MPFS Proposed Rule Details Chronic Care Management Payment, Increases Transparency of Code Revaluations, Continues Implementation of Quality Programs

Published

Jul 09, 2014

On July 3, CMS released the Calendar Year (CY) 2015 Medicare Physician Fee Schedule (MPFS) proposed rule.

This rule updates the relative value units (RVUs) used to calculate physician payments and changes to various payment policies and quality programs for physicians and other qualified healthcare professionals.  Among other things, CMS showed that they remain focused on primary care by detailing payment policy for chronic care management, as well as continued focus on transparency.

CMS largely avoided major physician payment policy changes in this proposed rule. For CY 2016, CMS proposes to increased transparency and allow public comment on the rate setting process for new, revised, and potentially misvalued services. The timing for requesting new or revised Current Procedural Terminology (CPT®) codes will be increasingly important in order to meet the cutoff date for inclusion in the proposed rule.  CMS also proposed several changes to quality measure reporting for the Medicare Shared Savings Program (MSSP), including a modifier for physician services rendered in off-campus facility settings. 

Comments are due to CMS by Sep. 2, and a final rule will likely be released in November.  Proposed RVUs and rates would go into effect between Jan. 1 and March 31, 2015, unless Congress extends the Sustainable Growth Rate (SGR) “fix” passed in the Protecting Access to Medicare Act (PAMA) of 2014. If Congress fails to pass any SGR legislation by April 1, the cut to physician payments is estimated to be 20.9 percent.

View CMS’ full proposed MPFS rule.

For specific MPFS related questions, contact Adam Borden at ABorden@Avalere.com.

Other Select Highlights Include: 

  • Elimination of Global Surgery Periods: CMS proposes to phase out 10-day and 90-day global surgery periods, due to concerns with inaccuracies of post-service visits. Under the proposal, 10-day global periods would become 0-days in 2017, with 90-day global periods shifting to 0-days in 2018.
  • Changes to Open Payments Program (Sunshine Act): Proposed changes include eliminating the continuing education exclusion, reporting of the marketed name of the product, and reporting of stocks, options or other ownership as distinct categories.
  • Downward Payment Adjustments Begin for Eligible Providers (EPs) Not Reporting Under Physician Quality Reporting Program (PQRS): In 2015, non-participating EPs in the PQRS or in a qualified clinical data registry (QCDR) will see a -1.5 percent reduction to their Medicare allowed amounts. For 2015 PQRS reporting, CMS proposes various changes to measures including 28 new measures, 2 new measure groups, and removal of 73 measures.
  • Continued Phase-In of Value Based Payment Modifier (VBPM): CMS proposes to apply the VBPM beginning in CY 2017 to all physicians, based on information reported in 2015. 
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