CMS Releases Final 2018 Physician Fee Schedule and Hospital Outpatient Rules

On Nov. 2, the Centers for Medicare and Medicaid Services (CMS) released the final ruling on the 2018 Medicare Physician Fee Schedule (PFS), addressing Medicare payment rates and policy provisions for physicians in 2018. Physicians will see a less than 0.1 percent conversion factor payment increase starting Jan. 1, 2018. CMS estimates that the rule will increase payments to cardiologists by 1 percent from 2017 to 2018. This estimate is based on the entire cardiology profession and can vary widely depending on the mix of services provided in a practice.

The release of the PFS rule follows the late-October release of the final rule for the 2018 Hospital Outpatient Prospective Payment System (OPPS), which indicates a 1.75 percent payment update for hospitals.

Additional highlights from both final rules include –

Physician Fee Schedule

  • Changes to the implementation of the new appropriate use criteria (AUC) requirement for advanced imaging services (i.e., SPECT MPI, CT and MR). Specifically:
    • Deferral of the requirement that ordering professionals consult with AUC through a qualified clinical decision support mechanism (CDSM) until Jan. 1, 2020, delaying this requirement two years.
    • The 2020 reporting year will be used testing and education.
    • CMS will further evaluate hardship exceptions to the requirement to consult AUC and report data after hearing critical feedback from stakeholders.
  • No updating malpractice Relative Value Units (RVUs) with inaccurate premium data in a manner that would negatively impact cardiologists who perform surgical procedures.
  • Reduced payment rates for certain items and services furnished by off-campus hospital provider-based departments from 50 percent of OPPS to 40 percent of OPPS.
  • Updated values for stress echocardiography, transthoracic echocardiography, electrophysiology (EP) device monitoring services, EP 3D mapping add-on services and extremity angiography radiological supervision and interpretation, resulting from previously directed reviews of work and practice expense inputs. More detail will be available following CMS’ posting of supporting data tables.
  • Finalized values for new codes describing International Normalized Ratio (INR) anticoagulation management billed per test, regardless of where the test result is obtained and endovenous ablation of incompetent extremity veins.
  • Net reduction in expenditures resulting from adjustments to misvalued codes of 0.41 percent, missing the 2018 statutory target of 0.50 percent. The remaining 0.09 percent will be removed through an across-the-board reduction to all fee schedule services.
  • To align with MIPS requirements, clinicians and groups who successfully reported six quality measures for the 2016 Physician Quality Reporting Program will avoid the -2 percent penalty that was to be applied in 2018. This is a reduction from the required nine measures across three National Quality Strategy domains. Additionally, the maximum penalties for the Value-Based Payment Modifier would be reduced from -4 percent to -2 percent for groups of 10 or more and -2 percent to -1 percent for groups of 10 or fewer.
  • Creation of five Level II Healthcare Common Procedure Coding System (HCPCS) modifiers used to capture patient relationship categories required by MACRA for improved cost measurement. Voluntary use of these modifiers can begin on Jan. 1, 2018.

Hospital Outpatient Prospective Payment Rule

Based on the policies in the final rule, CMS estimates an overall 1.4 percent payment increase for services paid under the OPPS in 2018. CMS finalized several recommendations made by your ACC including –

  • Maintaining the 2017 ambulatory payment classification (APC) structure for imaging procedures, maintaining payment stability for services such as cardiac MR and contrast echocardiography.
  • Addition of AMI PCI (CPT 92941) to the inpatient-only list to alleviate two-midnight rule challenges for emergent AMI patients.
  • Reinstating the non-enforcement of direct supervision requirements for outpatient therapeutic services provided in Critical Access Hospitals and small rural hospitals for CY 2018 and 2019

"The ACC is pleased to see CMS finalize the requirement that clinicians consult with appropriate use criteria (AUC) for advanced imaging services starting in 2020 as an educational year, rather than 2018. The College hopes that CMS will continue to work with stakeholders to ensure that the AUC program supports improved, cost-effective patient care without excessively burdensome requirements," said ACC President Mary Norine Walsh, MD, FACC. "The ACC is committed to the use of AUC in clinical decision-making and is pleased to see that CMS is providing additional time to prepare for this program."

ACC staff will continue to review the final rules to identify additional topics of interest to members. Other key points can be found in the CMS PFS Fact Sheet.

Keywords: Healthcare Common Procedure Coding System, Health Expenditures, International Normalized Ratio, Centers for Medicare and Medicaid Services (U.S.), Hospitals, Rural, Outpatients, Inpatients, Medicare, Fee Schedules, Medicaid, Ambulatory Care, Malpractice, Prospective Payment System

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