On July 13, 2017, the Centers for Medicare and Medicaid Services (CMS) released the calendar year 2018 Medicare Physician Fee Schedule (PFS) Proposed Rule. As the comment deadline is September 11, 2017, below are some important topics from the release to help you understand the proposed rule and what it may mean for you.
Evaluation and Management Comment Solicitation
CMS is seeking comments regarding changes to the documentation guidelines for E/M codes in order to decrease the related burden and better align E/M coding and documentation with the current practice of medicine. Specifically, CMS is initially focusing on the history and exam portions.
Emergency Department Visits Comment Solicitation
CMS is seeking comments on whether emergency department visits are undervalued due to the changing patient population and the increased diversity of the settings under which these services are provided.
Appropriate Use Criteria for Advanced Diagnostic Imaging
CMS is proposing to implement the Medicare Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging. This program is proposed to begin with an educational and operational testing year in 2019.
Physician Quality Reporting System (PQRS)
CMS is proposing to change the current PQRS program policy that requires the reporting of nine measures across three domains so that only six measures are required, aligning better with the requirements under the Merit-Based Incentive Payment System (MIPS).
Patient Relationship Codes
CMS is proposing the use of Level II HCPCS modifiers on claims to indicate patient relationship categories required by MACRA. They are proposing voluntary reporting of these codes beginning January 1, 2018.
2018 Value Modifier
CMS is proposing to reduce the penalties under the Physician Value-Based Modifier (VM) program for those that did not meet the minimum quality reporting requirements. There would be no negative VM payment adjustment for 2018 for any practice that met 2016 PQRS reporting requirements. If the practice did not meet the PQRS reporting requirements, the penalties would be reduced. The penalties for groups of ten or more would be reduced from -0.4% to -0.2%. For practices of one to nine, the penalties would be reduced from -0.2% to -0.1%.
We will continue to keep you informed as updates are made available.