CMS Proposes Changes to Physician Fee Schedule and Quality Payment Program

It turns out, the change from Advancing Care Information to Promoting Interoperability is part of something much bigger. So much bigger, that the Centers for Medicare & Medicaid Services (CMS) announcement said the proposed rules issued July 12, 2018 are “historic changes” to the Physician Fee Schedule (PFS) and Quality Payment Program (QPP).

“Today’s proposals deliver on the pledge to put patients over paperwork by enabling doctors to spend more time with their patients,” said CMS Administrator Seema Verma. “The proposed changes to the Physician Fee Schedule and Quality Payment Program address those problems head-on, by streamlining documentation requirements to focus on patient care and by modernizing payment policies so seniors and others covered by Medicare can take advantage of the latest technologies to get the quality care they need.”

Proposed Changes to the PFS for 2019

CMS received public feedback that indicated a need to streamline documentation requirements for Evaluation and Management (E&M) visits and a need to support greater access to care using telecommunications technology.

In response, CMS is proposing the following changes to the PFS that are said to reinforce their Patients Over Paperwork initiative:

Streamlining E&M Payment and Reducing Clinician Burden    

  • Simplify, streamline and offer flexibility in documentation requirements for E&M office visits — which make up about 20 percent of allowed charges under the PFS and consume much of clinicians’ time.
  • Reduce unnecessary physician supervision of radiologist assistants for diagnostic tests.
  • Remove burdensome and overly complex functional status reporting requirements for outpatient therapy.

Advancing Virtual Care

  • Paying clinicians for virtual check-ins – brief, non-face-to-face appointments via communications technology.
  • Paying clinicians for evaluation of patient-submitted photos.
  • Expanding Medicare-covered telehealth services to include prolonged preventive services. 

Lowering Drug Costs 

CMS is proposing changes as part of the continued rollout of the Administration’s blueprint to lower drug prices and reduce out-of-pocket costs. The changes would affect payment under Medicare Part B. Part B covers medicines that patients receive in a doctor’s office, such as infusions. CMS is proposing a change in the payment amount for new drugs under Part B, so that the payment amount would more closely match the actual cost of the drug. This change would be effective January 1, 2019 and would reduce the amount that seniors would have to pay out-of-pocket, especially for drugs with high launch prices

Proposed Changes to the QPP for 2019

The QPP was established as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The QPP consists of two participation pathways for doctors and other clinicians – MIPS, which measures performance in four categories to determine an adjustment to Medicare payment, and Advanced Alternative Payment Models (Advanced APMs), in which clinicians may earn an incentive payment through sufficient participation in risk-based payment models.

The proposed changes to QPP aim to reduce clinician burden, focus on outcomes, and promote interoperability of EHRs, including by:

  • Removing MIPS process-based quality measures that clinicians have said are low-value or low-priority, in order to focus on meaningful measures that have a greater impact on health outcomes
  • Overhauling the MIPS “Promoting Interoperability” performance category (previously “Advancing Care Information”) to support greater EHR interoperability and patient access to their health information, as well as to align this performance category for clinicians with the proposed new Promoting Interoperability program for hospitals.

Under the requirements of the Bipartisan Budget Act of 2018, CMS is continuing the gradual implementation of certain MIPS requirements to ease administrative burden on clinicians.

CMS also proposes waivers of MIPS requirements as part of testing a demonstration called the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) demonstration. The MAQI demonstration would test waiving MIPS reporting requirements and payment adjustments for clinicians who participate sufficiently in Medicare Advantage (MA) arrangements that are similar to Advanced APMs.

Price transparency Request for Comment

CMS is also seeking comment through a Request for Information asking whether providers and suppliers can and should be required to inform patients about charge and payment information for health care services and out-of-pocket costs, what data elements would be most useful to promote price shopping, and what other changes are needed to empower health care consumers

Public comments on the proposed rules are due by September 10. For more information, please click HERE.

Healthcare Compliance Pros is closely reviewing the proposed rules and will be providing additional information in subsequent newsletters. In the meantime, if you have any questions please do not hesitate to contact us.

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