Physician Fee Schedule 2018 Final Rule - December 11, 2017 powered by Vizient & AAMC
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powered by Vizient & AAMC Physician Fee Schedule 2018 Final Rule December 11, 2017 © 2017 Vizient, Inc. and AAMC Page 1
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Agenda • Payment Policies and Other Policies • Conversion Factors, Misvalued RVUs, RVU Targets • Payment Rates for Provider-Based Off Campus Hospital Departments • Payment for Telehealth • Other Proposals of Interest • Appropriate Use Criteria for Advanced Diagnostic Imaging • Patient Relationship Code Reporting • Expansion of Diabetes Prevention Program © 2017 Vizient, Inc. and AAMC Page 3
2018 Medicare Physician Fee Schedule Final Rule • Displayed November 2, published in Federal Register November 15 https://www.gpo.gov/fdsys/pkg/FR-2017-11-15/pdf/2017-23953.pdf • Supplemental materials (including RVU data) https://www.cms.gov/Medicare/Medicare-Fee-for-Service- Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1676-F.html © 2017 Vizient, Inc. and AAMC Page 4
Physician Fee Schedule Final Rule Proposed Rule Final Rule Proposed Rule Final rule comment provisions issued: July published: deadline: effective: 12, 2017 September November January 1, 15, 2017 11, 2017 2018 © 2017 Vizient, Inc. and AAMC Page 5
Separate Quality Programs are all Sunsetting PQRS Meaningful Use Program A New Consolidated Pay-for-Performance Value Program under Modifier Program MACRA Merit-Based Incentive Payment System (MIPS) © 2017 Vizient, Inc. and AAMC Page 6
Fee Schedule Remains Bedrock of Payment Fee Schedule © 2017 Vizient, Inc. and AAMC Page 7
Payment Policies © 2017 Vizient, Inc. and AAMC Page 8
Physician Fee Schedule (PFS) Updates • MACRA repealed Sustainable Growth Rate • PFS 0.5% update CY 2016-CY 2019 • PFS 0.0% update CY 2020-2025 • PFS updates 2026 and beyond: 0.75% for APM; 0.25% for MIPS • Merit-Based Incentive Payment System (MIPS) & participation in Alternative Payment Models will drive payment in 2019 and beyond © 2017 Vizient, Inc. and AAMC Page 9
MACRA Timeline © 2017 Vizient, Inc. and AAMC Page 10
Targets for “Misvalued” Code Reductions ABLE Legislation • 2016: 1.0% reduction established 3 years • 2017: .5% reduction of target reductions • 2018: .5% reduction for misvalued codes • If reductionstarget, then no adjustment to PFS, amount over target is applied to next year’s target 2018 reduction did • Target recapture of -0.09 percent (CMS achieved not meet the 0.5% .41% in reductions) target © 2017 Vizient, Inc. and AAMC Page 11
Calculation of 2018 PFS Conversion Factor Conversion Factor 2017 $35.8887 Update Factor 0.50 percent (1.0050) 2018 RVU Budget -0.10 percent (0.9990) Neutrality adjustment 2018 Target Recapture -0.09 percent (0.9991) Amount 2018 Conversion Factor $35.9996 © 2017 Vizient, Inc. and AAMC Page 12
Malpractice RVUs: No change in final rule • In proposed rule, CMS discussed updating malpractice relative units with new premium data and specialty risk factors. (use of new data would have negatively impacted many specialists). • Concerns raised that the proposed valuation changes were not indicative of what is actually occurring in professional liability market. • In final rule, CMS decides not to update malpractice data. They will continue to use the same data collected for the 2015 MP RVU update. • The next update must occur by 2020. © 2017 Vizient, Inc. and AAMC Page 13
CMS Analysis of Specialty Impact Social Worker (+ 3%) Diagnostic Testing Facility Clinical Psychologist (+2%) (-4%) Psychiatry (+1%) PT/OT (-2%) Infectious disease (+1%) Independent labs (-1%) Cardiology (+1%) Allergy/Immunology (-3%) Vascular Surgery (-1%) © 2017 Vizient, Inc. and AAMC Page 14
Overview • Coding changes (additions/deletions) – Diagnostic radiology – Artificial heart procedures and other Cardiology services – Esophagectomy additions – Collaborative care management • Specialty impact – Cardiology: Electrophysiology – Cardiology: Noninvasive – Pediatric Cardiology: Noninvasive – Pediatric Cardiology – Thoracic Surgery • GPCI gains and losses © 2017 Vizient, Inc. and AAMC Page 15
New Radiology Chest and Abdominal X-Ray Codes . Chest x-ray CPT codes 71010-71035 (described as Abdominal x-ray CPT codes 74000-74020 deleted ‘stereo’) deleted Abdominal x-ray CPT codes added based on number Chest x-ray CPT codes added based on number of of views views, simplifying code selection. Deleted CPT Codes New CPT Codes CPT CPT CPT Description 2017 wRVU CPT Description 2018 wRVU Code Code 71010 Chest x-ray 1 view frontal 0.18 71045 X-ray exam chest 1 view 0.18 71015 Chest x-ray stereo frontal 0.21 71046 X-ray exam chest 2 views 0.22 71020 Chest x-ray 2vw frontal&latl 0.22 71047 X-ray exam chest 3 views 0.27 71021 Chest x-ray frnt lat lordotc 0.27 71048 X-ray exam chest 4+ views 0.31 71022 Chest x-ray frnt lat oblique 0.31 71023 Chest x-ray and fluoroscopy 0.38 X-ray exam abdomen 1 74018 0.18 71030 Chest x-ray 4/> views 0.31 view 71034 Chest x-ray&fluoro 4/> views 0.46 X-ray exam abdomen 2 74019 0.23 71035 Chest x-ray special views 0.18 views X-ray exam abdomen 3+ 74021 0.27 74000 X-ray exam of abdomen 0.18 views 74010 X-ray exam of abdomen 0.23 74020 X-ray exam of abdomen 0.27 © 2017 Vizient, Inc. and AAMC Page 16
Total Heart Replacement System Codes Move from Category III to Category I • CPTs 33927-33929 replace 0051T-0053T Category III codes (emerging technologies, services and procedures. • 33927 will no longer be gap-filled and may receive fewer Work RVUs than in 2017 • 33928 and 33929 will be subject to FPSC gap-filling methodology 2018 2017 CPT Code CPT Description wRVU wRVU* 33927 Impltj tot rplcmt hrt sys 49.00 53.26 33928 Rmvl & rplcmt tot hrt sys 0 0 33929 Rmvl rplcmt hrt sys f/trnspl 0 0 * wRVUs calculated using the FPSC gap-filling methodology • Gap-filling is applied to codes with zero work, practice expense, and malpractice RVUs • Locally weight ratio of charges to RVUs © 2017 Vizient, Inc. and AAMC Page 17
Esophagectomy CPT codes 43286, 43287 and 43288 created to report esophagectomy via laparoscopic and thoracoscopic approaches. 2018 CPT Code CPT Description wRVU 43286 Esphg tot w/laps moblj 55.00 43287 Esphg dstl 2/3 w/laps moblj 63.00 43288 Esphg thrsc moblj 66.42 CPT codes 43107, 43112, and 43117 were also reviewed as part of the family with the three new codes. CPT code 43112 was revised to clarify the nature of the service being performed. – Additional specialty impact information detailed in following slide © 2017 Vizient, Inc. and AAMC Page 18
Collaborative Care Management Three new, time based codes for psychiatric collaborative care management (CoCM): 2018 CPT Code CPT Description wRVU 99492 1st psyc collab care mgmt; 70 min 1.70 99493 Sbsq psyc collab care mgmt; 60 min 1.53 99494 1st/sbsq psyc collab care; each additional 30 min 0.82 © 2017 Vizient, Inc. and AAMC Page 19
Specialty Impacts © 2017 Vizient, Inc. and AAMC Page 20
Cardiology: Electrophysiology Observed Overall Loss % Variance (2018 vs. 2017) Negative figures = reduction Work RVU Non Facility Total RVU Facility Total RVU per 1.0 cFTE per 1.0 cFTE per 1.0 cFTE -3.1% -1.7% -1.8% Mean Impact CPT 2018 2017 wRVU % CPT Description wRVU per 1.0 cFTE Code wRVU wRVU Change Change per MD Dev interrog remote 93295 0.74 1.29 -0.55 -43% -169 1/2/mlt Electrophys map 3d add- 93613 5.23 6.99 -1.76 -25% -132 on © 2017 Vizient, Inc. and AAMC Page 21
Adult and Pediatric Cardiology Echo w/Doppler Accounts for Overall Increase % Variance (2018 vs. 2017) Negative figures = reduction Mean Impact Non Facility Work RVU Facility Total RVU wRVU per Specialty Total RVU per 1.0 cFTE per 1.0 cFTE 1.0 cFTE per 1.0 cFTE per MD Cardiology: Noninvasive +2.3% +2.0% +2.1% +174 Pediatric Cardiology: Noninvasive +2.0% +1.7% +1.8% +102 Pediatric Cardiology +1.3% +1.2% +1.2% +60 CPT 2018 2017 wRVU % CPT Description Code wRVU wRVU Change Change 93306 Tte w/doppler complete 1.50 1.30 +0.20 +15% © 2017 Vizient, Inc. and AAMC Page 22
Surgery Thoracic Displays Increase Due to Esophagectomy wRVU Change % Variance (2018 vs. 2017) Negative figures = reduction Work RVU Non Facility Total RVU Facility Total RVU per 1.0 cFTE per 1.0 cFTE per 1.0 cFTE +1.0% +0.6% +0.7% Mean Impact CPT 2018 2017 wRVU % CPT Description wRVU per 1.0 cFTE Code wRVU wRVU Change Change per MD Partial removal of 43117 57.50 43.65 +13.9 +32% +43 esophagus 43112 Removal of esophagus 62.00 47.48 +14.5 +31% +29 43107 Removal of esophagus 52.05 44.18 +7.9 +18% +16 © 2017 Vizient, Inc. and AAMC Page 23
Geographic Pricing Cost Index (GPCI) Gains and Losses • Based on an average mix of Work, Practice Expense and Malpractice RVUs, we found • the following year-over-year changes from 2017 to 2018. a • The 1.0 Work GPCI floor required by Section 201 of the MACRA of 2015 expires on December 31, 2017, therefore the Work GPCIs for 2018 do not reflect a 1.0 floor. Decreases due to potential GPCI floor expiration 2018 2018 2018 Work 2018 2018 2018 Work Locality Name Work PE MP GPCI Locality Name Work PE MP GPCI GPCI GPCI GPCI % Change GPCI GPCI GPCI % Change Oklahoma 0.961 0.891 0.954 -4% Metro Boston 1.033 1.179 1.061 1% Rest of Missouri 0.961 0.863 0.993 -4% San Francisco Mississippi 0.961 0.870 0.370 -4% 1.075 1.325 0.421 1% (Alameda/Contra Costa West Virginia 0.966 0.857 1.296 -3% Cnty) Kansas 0.966 0.911 0.615 -3% Los Angeles (Orange Iowa 0.969 0.907 0.423 -3% 1.046 1.177 0.694 0.5% County) Indiana 0.969 0.919 0.379 -3% Nebraska 0.970 0.910 0.318 -3% Arkansas 0.971 0.872 0.576 -3% Kentucky 0.974 0.880 0.819 -3% © 2017 Vizient, Inc. and AAMC Page 24
Background: Payment for Off-Campus Provider-Based Hospital Departments Section 603 of Bipartisan Budget Act of 2015 requires payment for services furnished by off-campus provider based departments under Part B system other than Hospital Outpatient Prospective Payment System (OPPS). The new payment rate policy does not apply to hospitals that were furnishing covered OPD services before November 2, 2015. © 2017 Vizient, Inc. and AAMC Page 25
2017 Payment Rates for “Nonexcepted” Off Campus Outpatient Hospital Departments For 2017, CMS made the Physician Fee Schedule the payment system and set payment rates based on a 50-percent reduction to the OPPS payment rates (inclusive of packaging). The adjustment is referred to as the “PFS Relativity Adjuster” Must report a modifier “PN” on each UB 04 claim line to indicated nonexcepted items or service © 2017 Vizient, Inc. and AAMC Page 26
2018 Payment Rates for Off-Campus Provider- Based Hospital Departments CMS proposed 75 percent reduction in payment for nonexcepted services at off campus OPDs (current reduction is 50 percent) In response to comments, CMS finalizes a 60 percent reduction instead of 75 percent proposed. © 2017 Vizient, Inc. and AAMC Page 27
Other Off Campus Hospital Provisions • CMS specifies that all beneficiary cost-sharing rules that apply under the PFS will continue to apply to all nonexcepted items and services furnished by off-campus OPDs • The supervision rules continue to apply to off campus departments that furnish nonexcepted services © 2017 Vizient, Inc. and AAMC Page 28
Evaluation and Management (E/M) Documentation Guidelines CMS invited comments on: • Approaches to guideline revision that reduce burden and leverage electronic health technology • Revisions that deemphasize history and physician exam performance • Consideration of reducing or evening eliminating the history and physical exam components at all E/M code levels. • Extension of practitioner autonomy to determine volume of documentation • Guidelines structured to match documentation to patient complexity (particularly medical decision-making) © 2017 Vizient, Inc. and AAMC Page 29
Evaluation & Management Documentation Guidelines AAMC Comments CMS Final Rule • With increased use of EHR, and • CMS will consider these issues movement to team-based care, for future rulemaking, but the E&M guidelines impose a immediate focus will be on significant administrative burden revision of current E&M and are an impediment to good guidelines in an effort to reduce patient care. unnecessary administrative • For surgical/subspecialties, a burden. comprehensive exam is not always relevant. • Determination of the level of service should be based on medical decision-making, not time alone. © 2017 Vizient, Inc. and AAMC Page 30
Expansion of Telehealth Services CMS finalized the addition of the following codes: • HCPCS code G0296: Counseling visit to discuss the need for lung cancer screening using LDCT • CPT codes 90839 and 90840: Psychotherapy for crisis; first 60 minutes © 2017 Vizient, Inc. and AAMC Page 31
Expansion of Telehealth Services CMS finalized the addition of the following codes: • CPT code 90785: Interactive complexity • CPT codes 96160 and 96161: Administration of patient-focused health risk assessment instrument and Administration of caregiver- focused health risk assessment instrument • HCPCS code G0506: Comprehensive assessment or/and care planning for patients requiring chronic care management services © 2017 Vizient, Inc. and AAMC Page 32
Telehealth: Elimination of GT modifier • Effective January 1, 2017 Place of Service (POS) code 02 Telehealth is required on professional claims • CMS finalized the proposal to eliminate required use of the GT modifier on professional claims • Institutional claims, and federal telemedicine programs in AK and HI will need to continue using the GT modifier © 2017 Vizient, Inc. and AAMC Page 33
Telehealth: Remote Patient Monitoring • CMS activated separate payment for CPT code 99091, changing status from bundled • 99091: Collection and interpretation of physiological data digitally stored and/or transmitted by the patient and/or caregiver • Medicare allowed payment: $58.68 © 2017 Vizient, Inc. and AAMC Page 34
Appropriate Use Criteria (AUC) for Advanced Diagnostic Services Established by Protecting Access to Medicare Act of 2014 Criteria for physicians to better identify the appropriate advanced diagnostic imaging service: • Appropriate Use Criteria (AUC) must be developed by qualified provider-led entities (list published in June 2016). • Clinical decision support mechanism (CDSMs) are electronic tools physicians will use to access the AUC to determine appropriateness of advanced diagnostic imaging test. • Requirement that in future ordering physicians must begin consulting CDSMs and furnishing professionals must append AUC information about ordering physician’s consultation to Medicare claim. • Identification of Outlier physicians in the future. © 2017 Vizient, Inc. and AAMC Page 35
AUC Implementation CMS makes the AUC consultation and reporting requirements effective for an educational and operational testing period beginning on January 1, 2020. From mid-2018 through 2019, a voluntary physician participation period will run. In future, payment may only be made if the claim includes the proposed information required by furnishing professionals. It applies across the following payment systems (PFS, hospital outpatient, ASC) © 2017 Vizient, Inc. and AAMC Page 36
AUC Implementation: What is Required? Furnishing Professional: Must Ordering Professional report the following • Must consult AUC through • Must report: qualified CDSMs for tests • Which qualified CDSM was ordered on or after January consulted by ordering 1, 2020. professional • (delayed from statutory • Whether service ordered requirement of 2017). would adhere to AUC or not, or whether AUC not applicable; and • NPI of ordering professional CMS will continue to pay claims whether or not they correctly include appropriate information. © 2017 Vizient, Inc. and AAMC Page 37
New Coding Systems: MACRA • Statute required claims submitted after Jan. 1, 2018 must include: – Patient Condition Groups: Based on a patient’s chronic conditions, current health status, and recent significant history (e.g. hospitalization or surgery) (better risk adjustment) – Care Episode Groups: Create to define the types of procedures or services furnished for particular clinical conditions or diagnoses – Patient Relationship categories: Distinguish the relationship and responsibility of a physician with a patient at the time of furnishing the item/service. (accountability) © 2017 Vizient, Inc. and AAMC Page 38
Patient Relationship Modifiers • Beginning January 1, 2018 claims for services provider may voluntarily submit claims with modifiers. • Duration of voluntary modifier reporting period is not specified. © 2017 Vizient, Inc. and AAMC Page 39
Patient Relationship HCPCS Modifiers and Categories Number Proposed HCPCS Modifier Patient Relationship Categories 1x X1 Continuous/Broad Services 2x X2 Continuous/Focused Services 3x X3 Episodic/Broad Services 4x X4 Episodic/Focused Services 5X X5 Only as Ordered by Another Clinician © 2017 Vizient, Inc. and AAMC Page 40
Patient Relationship Modifiers Relationship Category Description Example Continuous/Broad Clinicians who provide the Primary care, specialists principal care for a patient, providing comprehensive where there is no planned care to patients in addition endpoint of the relationship to specialty care, etc Continuous/Focused Could include a specialist Rheumatologist taking care whose expertise is needed of a patient’s rheumatoid for the ongoing arthritis longitudinally but management of a chronic not providing general disease or a condition that primary care services needs to be managed and followed for a long time. Episodic/Broad Clinicians that have broad Hospitalist providing responsibility for the comprehensive and general comprehensive needs of the care to a patient while patients, but only during a admitted to the hospital. defined period and circumstance, such as a hospitalization. © 2017 Vizient, Inc. and AAMC Page 41
Patient Relationship Modifiers Relationship Category Description Example Episodic/Focused A specialist focused on An orthopedic surgeon particular types of time- performing a knee limited treatment. replacement and seeing the patient through the postoperative period. Only As Ordered By A clinician who furnishes A radiologist interpreting Another Clinician care to the patient only as an imaging study ordered ordered by another by another clinician clinician. © 2017 Vizient, Inc. and AAMC Page 42
2018 PQRS Payment Adjustment: Finalized Modifications • Reduced the number of required measures from 9 measures across 3 domains to 6 measures with no domain requirement (does not apply to Web Interface) • Eliminated requirement to report cross- cutting measure • Eliminated requirement that group practices of 100 or more EPS that use GPRO must administer to CAHPS for PQRS patient survey. © 2017 Vizient, Inc. and AAMC Page 43
2018 Value Modifier Program: Finalized Modifications Finalized modifications to VM policies for 2018 payment adjustment; would result in fewer EPs and groups receiving negative VM adjustment & size of positive adjustments would be reduced. All groups and practitioners that avoid the PQRS payment reduction will be held harmless from downward adjustments in quality tiering for 2018. Adjustment for those who fail to report PQRS are reduced from -4% to -2% for groups with 10 or more EPs and at least one physician. Reduced from -2% to -1% for groups with between 2 and 9 Eps, physician solo practitioners, non-physician EP groups. For groups with 10 or more EPs, maximum upward adjustment reduced from +4x to +2x and average quality would reduce from 2.0x to 1.0x. © 2017 Vizient, Inc. and AAMC Page 44
Expansion of Medicare’s Diabetes Prevention Program © 2017 Vizient, Inc. and AAMC Page 45
Medicare Diabetes Prevention Program (MDPP) What: Structured health behavior change program delivered in community and health care settings by training community health workers or health professionals, administered by Centers for Disease Control (CDC) Why: Diabetes affects more than 25% of Americans aged 65 or older and accounts for $104 billion annually which are anticipated to grow by 2050 Who: Targets individuals with prediabetes (individuals who have blood sugar higher than normal but not yet in the diabetes range) Program Structure: Consists of 16 intensive “core sessions” of a CDC-approved curriculum in a group- based setting that provides practical training in long-term dietary change, increased physical activity, and problem solving strategies for overcoming challenges to sustaining weight loss and a healthy lifestyle. Access to ongoing maintenance sessions after core benefit Goal: Reduce incidence of Type 2 diabetes by achieving at least 5 percent average weight loss among participants © 2017 Vizient, Inc. and AAMC Page 46
MDPP’s Finalized Requirements CMS Finalized Requirements Beneficiaries Eligibility Effective date beginning April 1, 2018 (instead of Pre-diabetic patient having a body mass index (BMI) of January 1, 2018) 25 or greater (BMI of 23 for Asian beneficiaries) Services begin April 1, 2018 Following blood levels: Providers can begin enrolling January 1, 2018 Hemoglobin A1c test with a value of 5.7-6.4 12-month program using the CDC-approved DPP percent or; curriculum a fasting plasma glucose of 110-125 mg/dL Beneficiaries can only enroll in MDPP once within last 12 months or; Beneficiaries who complete the 12 month program who 2-hour plasma glucose of 140-199 mg/dL after achieve and maintain required weight loss can be the 75 gram oral glucose tolerance test eligible for up to one year of monthly maintenance No previous diagnosis of diabetes (applies only at time sessions as long as weight loss is maintained of the first core session) Ongoing maintenance sessions adhere to the same curriculum requirements as the course Each MDPP session be at least an hour in duration Existing Medicare providers and suppliers must submit a separate enrollment application for MPDD services and with national provider identification (NPI) required © 2017 Vizient, Inc. and AAMC Page 47
MDPP Reimbursement • Number of Two Sessions Attended Factors • Achievement and Maintenance of Min. Weight Loss © 2017 Vizient, Inc. and AAMC Page 48
MDPP Reimbursement Performance Goal Payment Per Beneficiary Payment Per Beneficiary (with min. weight loss) (without min. weight loss) 1 session attended $25 4 sessions attended $50 9 sessions attended $90 2 sessions attended in 1 st $60 $15 core maintenance session interval (months 7-9) Weight loss of 5% $160 $0 achieved Advanced weight loss of $25 $0 9% achieved Max Total Performance $670 $195 payment © 2017 Vizient, Inc. and AAMC Page 49
Diabetes Prevention Program: Social Risk Factors • CMS requested comments about social risk factors in the context of the set of MDPP services for future consideration. • CMS will be reviewing comments made as they consider additional policies surrounding social risk factors in the future. © 2017 Vizient, Inc. and AAMC Page 50
Medicare Shared Savings Program Changes Revises assignment methodology for Adds 3 new chronic care assigning Medicare FFS management codes and beneficiaries to an ACO behavioral health based on utilization of integration codes to services furnished by definition of primary care rural health clinics and services federally qualified health care centers. Reduces burden for submitting an initial Makes changes for Shared Savings Program consistency with the application and MIPS program reporting application for use of SNF under MACRA 3 day waiver © 2017 Vizient, Inc. and AAMC Page 51
Resource links Medicare Physician Fee Schedule Final Rule https://www.gpo.gov/fdsys/pkg/FR-2017-11-15/pdf/2017-23953.pdf CMS Fact Sheet on Medicare Physician Fee Schedule https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet- items/2017-11-02.html AAMC Webpage: Physician Payment and Quality https://www.aamc.org/initiatives/patientcare/patientcarequality/311244/physicianpayment andquality.html © 2017 Vizient, Inc. and AAMC Page 52
Questions and Feedback Questions and Feedback about PFS Final Rule Gayle Lee, galee@aamc.org Kate Ogden, kogden@aamc.org FPSC Projects Related to PFS and Q&E Dave Troland, David.Troland@vizientinc.com Jake Langley, Jake.Langley@vizientinc.com © 2017 Vizient, Inc. and AAMC Page 53
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