CMS Physician Payment and Policy Changes Proposed for 2019

The Centers for Medicare & Medicaid Services (CMS) has proposed updates to payment policies, payment rates, and quality provisions for services provided under the Medicare Physician Fee Schedule (PFS) that will go into effect on January 1, 2019.

The calendar year (CY) 2019 Medicare PFS proposal includes the following changes:

• The proposal aims to reduce administrative burden and improve accuracy for evaluation and management (E/M) visits by focusing on the following points:
  
  • Allowing clinicians to choose to document office and outpatient E/M visits using medical decision-making or time
  • Expanding current options by allowing clinicians to use time as the governing factor in selecting visit level and documenting the E/M visit
  • Expanding current options for the documentation of history and examination, allowing clinicians to focus documentation on new and pertinent information
  • Allowing clinicians to review and verify information in the medical record rather than re-entering information 

• CMS has proposed single blended payment rates with a series of add-on codes that will apply to both new and established patients for office and outpatient E/M level 2 to 5 visits, which they believe will improve payment accuracy and simplify the documentation process. They have also proposed eliminating the need to justify the necessity of a home visit vs an office visit.  They have also removed duplicating notations for teaching physicians that may have been previously documented by residents or other medical staff.
•  In order to accommodate new, technology-based services, the CY 2019 PFS proposal defines 2 new services that they will pay separately for:
  
  • Brief Communication Technology-based Service (eg, Virtual Check-in)
  • Remote Evaluation of Recorded Video and/or Images Submitted by the Patient
• Providers of outpatient therapy services will no longer be required to include functional status information on claims for therapy services.
• The CY 2019 Medicare PFS has updated practice expense relative value units (RVUs) for approximately 1300 supplies and 750 equipment items. To ensure a smooth transition of past practice expense RVUs, these will be implemented over a 4-year period beginning in 2019.

• The CY 2019 Medicare PFS will recognize and pay for communication technology-based and remote evaluation services rendered by rural health clinics (RHCs) and federally qualified health centers (FQHCs).
• Many Part B drug payments include an add-on payment of 6% of the average sales price amount. This will be reduced to 3%, which may reduce excessive spending.
• The number of measures in the Medicare Shared Savings Program quality measure set will be reduced from 31 to 24, with a focus on outcome-based measures.
• The significant hardship criteria in the Appropriate Use Criteria (AUC) program will now include
  
  • Insufficient internet access
  • Electronic health record (EHR) or clinical decision support mechanism (CDSM) vendor issues
  • Extreme and uncontrollable circumstances
  • The CY 2019 PFS includes changes to the Quality Payment Program (QPP) that aim to reduce clinician burden, focus on outcomes, and promote interoperability of EHRs by:
  • Removing Merit-based Incentive Payment System (MIPS) process-based quality measures that clinicians have said are low value or low priority
  • Overhauling the MIPS “Promoting Interoperability” category

CMS is seeking clinician input on their new proposals, including how they might change their documentation guidelines in subsequent years. To read the full proposal for CY 2019 PFS, visit the CMS website.

Reference

Proposed policy, payment, and quality provisions changes to Medicare physician fee schedule for calendar year 2019. Centers for Medicare and Medicaid Services. https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-07-12-2.html. Published July 12, 2019. Accessed July 16, 2018.