On July 12 the Centers for Medicare & Medicaid Services (CMS) released the proposed rule that addresses changes to the 2019 Medicare Physician Fee Schedule (PFS) as well as proposed policies for Year 3 of the Quality Payment Program (QPP).
A CMS fact sheet highlights proposed changes to the PFS, and the entire proposed rule is available for review. Comments can be submitted to CMS until 5 p.m. on Sept. 10. The AASM is reviewing the proposed rule and will submit comments to CMS to advocate on behalf of the AASM membership.
Several highlights of the proposed changes to the PFS include:
- Streamlining evaluation and management (E/M) payment and reducing clinician burden
- Modernizing Medicare physician payment by recognizing communication technology-based services
- Discontinuing functional status reporting requirements for outpatient therapy
- Increasing the 2019 PFS conversion factor from $35.99 in 2018 to $36.05.
- Practice expense: Market-based supply and equipment pricing update
- Payment rates for non-excepted off-campus provider-based hospital departments paid under the PFS
- Expanding telehealth services and reimbursements
- Wholesale Acquisition Cost-based payment for Part B drugs: proposal to alter add-on amount
- Aligning the Medicare Shared Savings Program Accountable Care Organization with the Meaningful Measures initiative
- Issuing a request for Information on price transparency
Another CMS fact sheet highlights proposed changes to the QPP. Key proposals for Year 3 of the QPP include:
- Expanding the definition of Merit-based Incentive Payment System (MIPS) eligible clinicians to include new clinician types (physical therapists, occupational therapists, clinical social workers, and clinical psychologists)
- Adding a third element (Number of Covered Professional Services) to the low-volume threshold determination and providing an opt-in policy that offers eligible clinicians who meet or exceed one or two, but not all, elements of the low-volume threshold the ability to participate in MIPS
- Providing the option to use facility-based scoring for facility-based clinicians that doesn’t require data submission
- Modifying the MIPS Promoting Interoperability (formerly Advancing Care Information) performance category to support greater electronic health record (EHR) interoperability and patient access while aligning with the proposed new Promoting Interoperability Program requirements for hospitals
- Moving clinicians to a smaller set of Objectives and Measures with scoring based on performance for the Promoting Interoperability performance category
- Continuing the small practice bonus, but including it in the Quality performance category score of clinicians in small practices instead of as a stand-alone bonus
- Streamlining the definition of a MIPS comparable measure in both the Advanced Alternative Payment Models (APMs) criteria and Other Payer Advanced APM criteria to reduce confusion and burden amongst payers and eligible clinicians submitting payment arrangement information to CMS
- Updating the MIPS APM measure sets that apply for purposes of the APM scoring standard
- Increasing flexibility for the All-Payer Combination Option and Other Payer Advanced APMs for non-Medicare payers to participate in the Quality Payment Program.
- Updating the Advanced APM Certified EHR Technology (CEHRT) threshold so that an Advanced APM must require that at least 75% of eligible clinicians in each APM Entity use CEHRT.
- Extending the 8% revenue-based nominal amount standard for Advanced APMs through performance year 2024.
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