CY 2019 Medicare Physician Fee Schedule Proposed Rule Posted

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CY 2019 Medicare Physician Fee Schedule Proposed Rule Posted

The CY 2019 Medicare Physician Fee Schedule Proposed Rule with comment period was recently released and will be officially published in the Federal Register on July 27, 2018. This proposed rule updates payment policies, payment rates, and other provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after Jan. 1, 2019.

The Centers for Medicare and Medicaid Services (CMS) is proposing several updates and new proposals affecting the payment rates. These proposals include, but are not limited to: 

  1. Changes to office/outpatient Evaluation and Management (E/M) visit documentation, coding and payment.
  2. Payment for services provided through the use of communication technology such as virtual check-in and specified remote evaluation and monitoring, separately for two newly defined physicians' services furnished using communication technology.
  3. Adding HCPCS codes G0513 and G0514 to the list of telehealth services.
  4. Changing the way Medicare Advantage payments are treated in the definition of "applicable laboratories" under the clinical laboratory fee schedule and seeking comment on alternative approaches to for defining "applicable laboratories."
  5. Further aligning CMS' value-based payment initiatives with other programs and shared goals while focusing less on low-value or low-priority measures and more on interoperability of electronic health records and measures and incentives that potentially have a greater impact on health outcomes.

CMS is also seeking comments to assist in the care of persons with substance use disorders. Comments on creating a bundled episode of care for management and counseling treatment, necessary regulatory changes to help prevent opioid use disorder and improve access to treatment under the Medicare program, and methods for identifying non-opioid alternatives for and barriers to pain treatment and management are encouraged.

Price transparency is another area in which CMS is seeking direction from the public and health care community. Specifically, CMS is requesting input on barriers preventing providers and suppliers from informing patients of their out-of-pocket costs; what changes are needed to support greater transparency around patient obligations for their out-of-pocket costs; what can be done to better inform patients of these obligations; and what role providers of health care services and suppliers should play in this initiative.

Finally, CMS recommends the 2019 PFS conversion factor be $36.05, which would be a slight increase above the 2018 PFS conversion factor of $35.99.

For more details about the proposed rule, please review the CMS news release. Comments on the proposed rule will be accepted until September 10, 2018. The proposed rule can be downloaded from the Federal Register.

MSMS staff is currently reviewing the proposed rule and will be preparing comments for submission. If you have specific examples of how the proposed rule may negatively or positively impact your practice that you would like to share with MSMS, please feel free to email them to Stacey Hettiger, MSMS Director, Medical and Regulatory Policy.