CMS Proposed Rule Offers New SNF Specialty Measure Set and Other Big Changes

Late last week, the Centers for Medicare & Medicaid Services (CMS) published the proposed Physician Fee Schedule Rule for 2019.  It includes provisions for the Quality Payment Program (QPP) for 2019 as well as the physician fee schedule.  AMDA staff is reading the 1,473-page proposed rule and will develop comments prior to the September 10 deadline.

Here are some highlights of the Merit-based Incentive Payment System (MIPS) proposals:

• Proposing new and modified MIPS Specialty Measure Sets for the 2021 MIPS payment year and future years, including a new Skilled Nursing Facility Specialty Set
• Seeking comments on the expansion of facility-based measurement to use in other settings, including post-acute care

• Retaining the low-volume threshold but add a third criterion of providing fewer than 200 covered professional services to Part B patients.  

• Retaining bonus points for:
  • Care of complex patients
  • End-to-end reporting
  • Small practices
• Allowing eligible clinicians to opt in if they meet one or two, but not all, of the low-volume threshold criterion.
• Consolidating the low-volume threshold determination periods with the determination period for identifying a small practice.
• Eliminating the base and performance categories and reducing the number of measures in the Promoting Interoperability category.
• Requiring eligible clinicians to move to 2015 CEHRT.
• Providing the option to use facility-based scoring for facility-based clinicians.
• For the 2019 performance year the weights are:
  • Quality: 45%
  • Cost: 15%
  • Promoting Interoperability: 25%
  • Improvement Activities: 15%

This is a summary of the key Medicare Fee Schedule proposals:

• With the budget neutrality adjustment to account for relative value changes, as required by law, the proposed 2019 PFS conversion factor is $36.05, a slight increase above the 2018 PFS conversion factor of $35.99.
• CMS is not proposing to remove the frequency limitation (once every 30 days) for subsequent nursing facility care services (99307-993010) in CY 2019 for Medicare Telehealth Services.
• CMS has proposed to collapse payment for office and outpatient visits. New patient office visit (99202-99205) payments would be blended to be $135. Established office visits (99212-99215) would be blended to be paid at $93. New codes would be created to provide add-on payments to office visits for specific specialties ($9) and primary care physicians ($5). 
• To replace existing documentation guidelines, CMS proposes to allow use of (1) 1995 or 1997 documentation guidelines, (2) medical decision-making or (3) time. Documentation for history and exams will focus on interval history since last visit. Physicians will be allowed to review and verify certain information in the medical record entered by ancillary staff or the beneficiary, rather than re-entering the information.
• When physicians report an E/M service and a procedure on the same date, CMS proposes to implement a 50% multiple procedure reduction to the lower paid of the two services.
• CMS will implement new CPT codes and payment for remote monitoring and interprofessional consultations.
• CMS updated supplies and equipment pricing. The re-pricing of antigens has a significant impact on allergy and immunology payments, with an estimated 6% reduction for the specialty.

As always, AMDA welcomes any feedback from members to help develop our comments. They can be emailed to publicpolicy@paltc.org.