The Centers for Medicare and Medicaid Services (CMS) on July 3 released the 2015 Physician Fee Schedule proposed rule, covering payments and related policies for services provided by physicians or in the physician office setting. After thoroughly reviewing the rule, the ACC will submit comments at the end of the summer. The rule indicates that physicians will see no change in payment for the first three months of 2015 due to the latest sustainable growth rate (SGR) patch. However, the SGR will take effect April 1, 2015, unless Congress once again intervenes. At that time physicians would face a 20.9 percent cut as a result of the legally mandated SGR. As in previous years, the ACC continues to fight to avoid cuts to Medicare payment for cardiovascular services. Aside from the across-the-board cuts associated with the SGR, CMS estimates that the physician rule will increase payments by 1 percent to cardiologists from 2014 to 2015. This estimate is based on typical practice and can vary widely depending on the mix of services provided in a practice. You can view the impact on several key cardiology services here. Some of the key provisions of the physician fee schedule rule include:

Global Periods

In response to an Office of the Inspector General report about provision of follow-up evaluation and management services and other concerns about misvaluation of surgical services, CMS proposes to transition all 10- and 90-day global period codes to 0-day global periods. Services with 10-day global periods would be revised for calendar year (CY) 2017. Services with 90-day global periods would follow in CY 2018. CMS thinks that a greater diversity of services, procedure settings, follow-up care settings, and payment models along with a lack of regular updates to payment rates for these services necessitate such a change.

Potentially Misvalued Services

CMS seeks review of 65 services with Medicare allowed charges of $10 million or more as a prioritized subset of codes under the newly established statutory category of "codes that account for the majority of spending under the physician fee schedule." This list includes SPECT MPI, transthoracic echocardiography, stress echocardiography, and cardiac device monitoring services.

Open Payments (Sunshine Act)

CMS proposes to delete the exception in the Open Payments Program (Physician Payments Sunshine Act) for reporting of indirect payments by industry to physicians serving as faculty for accredited and/or certified continuing medical education. CMS believes eliminating the exemption for payments to speakers at certain accredited or certifying continuing medical education events will create a more consistent reporting requirement, and will also be more consistent for consumers who will ultimately have access to the reported data.

Complex Chronic Care Management

Medicare continues to emphasize care coordination services by beginning to make separate payment for chronic care management (CCM) services beginning in 2015. Last year, CMS established policy to make separate payment for non-face-to-face chronic care management services for Medicare beneficiaries who have multiple, significant chronic conditions (two or more). CCM services include regular development and revision of a plan of care, communication with other treating health professionals, and medication management.

Off-Campus Provider-Based Departments

To better understand the effect of hospital-owned practices on payment trends, CMS proposes to create a Healthcare Common Procedure Coding System modifier to be reported with every code furnished in this setting beginning Jan. 1, 2015. The Medicare Payment Advisory Commission and some in the provider community continue to question the appropriateness of increased Medicare payment and beneficiary cost-sharing when physician offices become hospital outpatient departments.

Physician Quality Reporting System

CMS proposes removal of six measures groups for reporting beginning in 2015: perioperative care, back pain, cardiovascular prevention, ischemic vascular disease (IVD), sleep apnea, and chronic obstructive pulmonary disease. The cardiovascular prevention measures group and IVD measures group are proposed for removal because a number of individual measures within these groups are proposed for removal from all Physician Quality Reporting System (PQRS) reporting options with the exception of electronic health record reporting.

Qualified Clinical Data Registry

The rule includes a proposal that an eligible professional wishing to meet the proposed criterion for satisfactory participation in a qualified clinical data registry (QCDR) for the 2017 PQRS payment adjustment report on at least three outcome measures (or if less than three outcome measures are available for reporting, report on at least two outcome measures and at least one of the following types of measures: resource use, patient experience of care, or efficiency/appropriate use). CMS would also amend the requirement for the 2017 PQRS payment adjustment to require a QCDR to possess at least three outcome measures, or the exception noted above. CMS proposes to continue the minimum number of measures a QCDR may report for the PQRS, as well as limit the number of non-PQRS measures that a QDCR may submit on behalf of an eligible professional at this time.

Value-Based Payment Modifier

CMS proposes to apply the value-based payment modifier (VM) to all physicians and physician practices starting in 2017. The proposed rule also increases the amount of payment subject to an upward or downward adjustment under the VM from 2 percent in 2016, to 4 percent in 2017.

Physician Compare

As finalized in the 2014 Physician Fee Schedule final rule, CMS will publicly report the names of eligible providers who report the 2014 PQRS Cardiovascular Prevention measures group in support of the Million Hearts Initiative on Physician Compare in 2015.

CMS proposes to expand public reporting of group-level measures by making all 2015 PQRS Group Practice Reporting Option (GPRO) measure sets across group reporting mechanisms available for public reporting on Physician Compare in 2016 for groups of two or more eligible professionals. In order to facilitate public reporting, CMS seeks comment on creating composite 2016 scores using 2015 data from certain PQRS GPRO measure groups.

Also for 2016, all QCDR data available for public reporting would be provided on Physician Compare on an individual level, or at a higher level (i.e. group practice) at the QCDR’s choosing. The QCDR would be permitted to post data on their own website via a Physician Compare link, or provide CMS with the data for public reporting directly through Physician Compare.

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