On July 8 the Centers for Medicare & Medicaid Services (CMS) issued the display copy of the 2014 Medicare Physician Fee Schedule proposed rule, which reflects proposed updates to payment policies and payment rates for services billed on or after Jan. 1, 2014. The proposed rule was published in the Federal Register on July 19. All policies and rates outlined in the proposed rule are subject to public comment. Following the close of the public comment period, CMS will modify and finalize policies and rates for 2014 in a subsequent final rule with an expected publication date of Nov. 1, 2013. For more information download the AASM Summary: 2014 Medicare Physician Fee Schedule Proposed Rule.
The field of sleep medicine is projected to experience cuts to payment for all services in 2014. If implemented, a proposed cut to the practice expense relative value units (RVUs) will result in decreased payment for sleep services that are billed globally. When billed separately, reimbursement for the technical component of the service also will be decreased while payment for the physician component of the service will be increased slightly. For more detailed payment information, download the CMS Sleep Services Payment Comparison.
This analysis assumes that Congress will again take legislative action to avert the looming cut to the conversion factor based on the sustainable growth rate (SGR) formula. Failure to do so would drastically reduce physician reimbursement by cutting the CMS conversion factor by more than 24%. The AASM is actively following legislation introduced to repeal the SGR formula, which would permanently avert such substantial cuts to Medicare payment.
Sleep physicians also can expect a change to their Physician Quality Reporting System (PQRS) requirements in 2014. The PQRS program, which began in 2007, incorporated a sleep-specific reporting option in 2012. The sleep apnea measures group contains four measures, which for 2013 must be reported for 20 patients in order to earn an incentive and successfully avoid a payment penalty. The proposed rule includes a new requirement that all measures groups include a minimum of six measures. To meet this new requirement, CMS proposes to expand the sleep apnea measures group from four to seven measures.
The AASM is developing comments to submit to CMS regarding the impact of proposed changes on sleep physicians. The following two key points will be addressed:
- Eliminate Payment Cuts: Sleep medicine has experienced substantial cuts to Medicare reimbursement over the past four years. The additional round of cuts proposed for 2014 will make it increasingly difficult for sleep physicians to continue to treat Medicare patients.
- Modify PQRS Proposal: The AASM will recommend that the sleep apnea measures group be expanded to include two new measures, not three. This will allow the measures group to meet the minimum six measure requirement CMS has proposed while limiting the burden to sleep physicians.
The AASM will publicize comment letters to CMS regarding the proposed rule in future editions of the Weekly Update.