If the policies set forth in the 2015 Medicare Physician Fee Schedule proposed rule take effect, physicians will be in for a lot of changes—many of them unfavorable—next year. Here are the top eight things that should be on your radar:
1. A 21 percent payment cut is scheduled for April 1. The Centers for Medicare & Medicaid Services (CMS) observed in a fact sheet that current payment rates will apply through March as a result of the temporary payment patch enacted earlier this year and projected that payment rates will be cut by 20.9 percent April 1 unless Congress intervenes. The agency stated its support for repeal of the flawed sustainable growth rate formula that has triggered such large cuts.
2. Global surgical packages will be eliminated. The rule proposes to discontinue all 10-day global surgical packages by 2017 and 90-day packages the following year. Packages instead would include only preoperative care and care given the day of surgery. Consistent with longstanding AMA policy, the AMA plans to work with the affected medical specialty societies to protest this proposed change.
3. Payments will be adjusted by the Value-Based Payment Modifier beginning next year. Despite continued AMA opposition, CMS plans to levy steeper payment adjustments and to continue basing the adjustments on costs and quality data two years before the adjustment is applied. Physicians in groups of 100 or more will see payment penalties or bonuses next year, determined by their group's cost and quality performance in 2013. Bonuses and penalties based on 2014 performance will be applied to groups of 25-100 starting in 2016.
All physicians will be subject to the modifier beginning in 2017, at which point the potential penalty will double to 4 percent. The pool of money available for bonuses depends on how much is collected in penalties, so potential bonuses are not yet known.
4. Quality reporting requirements will be increased in the face of penalties. CMS has reiterated a 2 percent payment penalty for physicians who don't meet the 2015 Physician Quality Reporting System (PQRS) requirements and is proposing additional requirements physicians will need to fulfill. At the same time, the agency is proposing to cut the period physicians have to request an informal review of a PQRS penalty from 90 days to just 30 days.
5. PQRS data will be publicly reported. The rule proposes making all 2015 measure data from group practices available in 2016. The agency also is hoping it will be able to publish later that year individual measures for all physicians on Physician Compare, a website plagued by accuracy and usability problems since it launched in 2010.
6. Chronic care management services will be covered. Beginning next year, Medicare will pay $43.67 per patient per month for chronic care management provided by a physician's office and $32.58 for care provided by a facility. Such services involve non-face-to-face care coordination for patients with multiple serious chronic conditions that are expected to last at least 12 months or until death.
7. More telehealth services will be covered beginning in 2016. The proposed changes include greater access for patients in rural locations by expanding the number of rural sites.
8. A new timeline for changing physician codes and service values would take effect in 2016. This revised timeline will mean physicians can submit recommendations no later than Jan. 15 for the following year. The change not only will severely limit recommendations from the Relative Value Scale Update Committee (RUC) and CPT® Editorial Panel but also will increase the time for a new or revised code to be included in the Medicare fee schedule from 10-20 months to 20-27 months. The AMA already has suggested timeline revisions to CMS that would provide greater transparency and better alignment between relative value unit recommendations and the regulatory process.
Comments on the proposed rule are due Sept. 2. The AMA will circulate its draft comments to state and specialty medical associations in advance of the submission deadline.