On July 13, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule updating payment policies and payment rates for physicians under the Medicare Physician Fee Schedule (MPFS) for 2018. CMS estimates a 0% impact in payment for neurology and +1% for physical medicine and rehabilitation physicians; although, ultimately, the result could differ when the final rule is published in the fall.
A few key areas addressed in the proposed 2018 MPFS include:
Evaluation and Management (E/M) Guidelines. CMS is proposing a multi-year effort to revise the Evaluation and Management Guidelines in an effort to reduce administrative burden to physicians. CMS suggests that greater importance be placed on medical decision making and time spent performing the service while eliminating the focus on the guidelines related to history and physical examination.
Telehealth services. CMS is seeking comments on a number of codes related to telehealth, and is also proposing to eliminate the requirement for the use of a modifier for telehealth services. CMS is also specifically seeking information regarding ways they might further expand access to telehealth services within the current statutory authority and take full advantage of communication technologies.
Patient Relationship Categories. The Medicare Access and CHIP Reauthorization Act (MACRA) directed CMS to create new patient relationship codes that physicians would be required to report on claims starting in 2018 for the purposes of determining which physician would be held accountable for a patient’s cost of care. CMS proposes 5 patient relationship categories that would be identified by modifiers rather than codes that physicians could voluntarily opt to use to designate patient relationship categories on claim forms beginning January 1, 2018.
PQRS and MU Quality Reporting. In order to align the Physician Quality Reporting System (PQRS) CY2016 and Meaningful Use (MU) quality reporting requirements with the new quality reporting requirements under MIPS (which began Jan. 1 of this year), CMS is proposing to revise CY2016 PQRS and MU quality reporting requirements to only require physicians to report 6 measures with no domain or cross-cutting measure requirements.
Value-based Modifier (VM). CMS is proposing to hold all groups and solo practitioners who met 2016 PQRS reporting requirements harmless from any negative VM payment adjustments in 2018 as well as to halve penalties for those who did not meet PQRS requirements to -2 percent for groups with 10 or more eligible professionals, and to -1 percent for smaller groups and solo practitioners.
The public and the AANEM have the opportunity to comment by September 11, 2017, on these proposals to influence policies that are released in the final rule. A more detailed analysis of any changes to the RVUs related to EDX or neuromuscular medicine is forthcoming. Please contact the policy department at email@example.com
with any questions or concerns.