On October 30, 2016, the Center for Medicare and Medicaid Services (CMS) released the Final Rule
for the 2016 Medicare Physician Payment Schedule. This document and addendum updates payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) beginning on January 1, 2016. This rule also finalizes changes to several of the Medicare quality reporting initiatives including the Physician Quality Reporting System (PQRS), the Physician Value-Based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program.
Following is a summary of some of the changes that could affect AANEM members for the calendar year (CY) 2016.
Conversion Factor (CF)—The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) replaced the reduction in the PFS with a 0.5 percent update through the end of this year. The final CF for CY 2016 is $35.8279 which is down from the current CF of $35.9335.
Physician Quality Reporting System (PQRS)—CMS established the same criteria for satisfactory reporting to the PQRS program, which is reporting nine measures covering three National Quality Strategy (NQS) domains. If an eligible professional (EP) or group practice does not satisfactorily participate in PQRS for 2016, a 2 percent negative payment adjustment will be applied during 2018.
Value-based Payment Modifier—CMS will use 2016 as the performance period for the 2018 value modifier and continue to apply the 2018 value modifier based on participation in the PQRS by groups and solo practitioners. The application of the value modifier on 2018 payments will also be expanded to non-physician eligible professionals based on 2016 performance period.
Global Surgical Package—CMS stated its intention to continue to develop and implement a process to gather the information needed to more accurately value surgical services. CMS intends to issue a proposal in the 2017 PFS.
Refinement Panel—CMS did NOT finalize the proposal to eliminate the refinement panel process at this time. CMS will still have the ability to convene refinement panels for codes with interim values under circumstances where additional input provided by the panel is likely to add value as a supplement to notice and comment rulemaking.
Medicare Opt-out—prior to MACRA, physicians that wished to renew their opt-out were required to file new valid affidavits with their Medicare Administrative Contractors (MACs) every 2 years. CMS clarified in the 2016 PFS final rule that under MACRA, physicians that filed valid opt-out affidavits on our after June 16, 2015, are not required to file renewal affidavits.
AANEM staff is currently analyzing the final rule for relative value unit (RVU) adjustments to electrodiagnostic and neuromuscular medicine specific codes as well as the effect any changes will have on reimbursement. Visit our website here
for the 2016 RVU analysis as it becomes available.
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