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Summary of Provisions from Physician Fee Schedule Proposed Rule for 2013



Summary of Provisions from Physician Fee Schedule Proposed Rule for 2013

Sustainable Growth Rate (SGR)CMS announcement

Physician Quality Reporting System (PQRS)

Medicare Shared Savings Program (MSSP)

Value-Based Payment Modifier (VBM)

Physician Feedback Reporting Program

Electronic Prescribing (eRx) Incentive Program

Care Coordination

Geographic Practice Cost Indices (GPCIs)

Multiple Procedure Payment Reduction

Certified Registered Nurse Anesthetists and Chronic Pain Management Services

Elimination of Requirement to Terminate Prepayment Medical Review

Face-to-Face Requirement for Durable Medical Equipment


Sustainable Growth Rate (SGR)

CMS projects a 27% Medicare physician payment cut to take effect on January 1, 2013.

Physician Quality Reporting System (PQRS)

For 2013 and 2014, CMS proposes to include 264 individual measures for PQRS, along with 26 measures groups for 2013.

To align various CMS quality payment programs, CMS proposes to align PQRS measures available for EHR-based reporting with measures under the EHR Incentive Program. Reporting measures via the PQRS Group Practice Reporting Option (GPRO) web-interface with be aligned with measures required under the MSSP.

Successful participation in the 2013 or 2014 PQRS program will result I a 0.5% incentive payment (based on estimated total allowed charges for all covered services during the reporting period). Qualifying for an incentive payment in 2013 and 2014 allows an EP to avoid penalties in 2015 and 2016.

To increase participation in PQRS, CMS proposes:

  • The minimum number of patients on which EPs are required to report using measure groups via the claims and registry reporting option would be decreased to 20 for 12-month and 6-month 2013 and 2014 incentive reporting periods.
  • Definition of a group practice would be expanded to include groups of 2-24 EPs.
  • Expand the use of the claims, registry, and EHR-based reporting mechanisms to group practices of 2-99 EPs.

To avoid penalty in 2015 and 2016, CMS proposes two additional reporting options:

  • Satisfactory reporting 1 PQRS measure or measures group using the claims, registry, or EHR-based reporting mechanisms during the 12 month reporting period (2013 and 2014, respectively).
  • Elect the proposed administrative claims-based reporting option for a proposed set of administrative claims-based measures. This proposed mechanism does not require an EP to submit quality data codes (QDCs) on Medicare Part B claims.

Medicare Shared Savings Program (MSSP)

CMS proposes to use same quality measures and reporting criteria for MSSP and PQRS programs.

MSSP EPs are also on the hook for PQRS penalties, and must comply with the MSSP requirements for satisfactory participation in the PQRS GPRO web-interface.

Value-Based Payment Modifier (VBM)

Created in the Patient Protection and Affordable Care Act (ACA), the VBM will lead to payment adjustments based on comparison of physicians’ cost and quality.

VBM must be applied to some physicians in 2015 and to all physicians in 2017.

CMS plans to base 2015 payment adjustments on data from 2013.

For groups that were not successful PQRS participants, 2015 Medicare payment rate will be cut by 1%. Those that were successful could either take a zero payment adjustment in 2015 or opt to be judged through a three-tiered system (lower tier participants would face a 1% payment cut; middle tier would see no change; top tier would receive an increase).

Physician Feedback Reporting Program

Starting in fall of 2014, physicians in groups of 25 or more will receive a confidential feedback report that includes the VBM that will be applied to the physicians’ payments in 2015.

Distribution of reports using more recent data will be expanded to include California in fall of 2012.

Electronic Prescribing (eRx) Incentive Program

CMS proposes improvements to the eRx program by:

  • Adding 2 hardship exemption categories tied to the participation in the meaningful use electronic health record incentive program (would be easier to avoid eRx penalties in 2013 and 2014).
  • Establishing a process that physicians encountering problems associated with 2013 eRx incentives and 2014 penalty program can request CMS review.
  • Lowering the reporting requirement for eligible group practices of 2-24 health care professionals.

Care Coordination

CMS outlines initiatives developed to date to incentivize and promote improved care coordination, including:

  • MSSP (Pioneer ACO Model and Advance Payment ACO Model)
  • Primary Care Incentive Payment (PCIP) Program
  • Multi-payor Advanced Primary Care Practice (MAPCP) Demonstration
  • Federally Qualified Health Center (FQHC) Advanced Primary Care Practice Demonstration
  • Comprehensive Primary Care (CPC) Initiative

For 2013, CMS proposes to implement fee-for-service payment for care coordination services. CPT codes developed for transitional care management from a facility to the community will be available for the 2013 Medicare physician fee schedule.

Monthly management codes and valuations to describe complex chronic care coordination services are also in development.

CMS is also calling for comments regarding how to pay for the medical home concept within fee-for-service, specifically on:

  • How to determine whether a physician practice should be considered an advanced primary care practice (i.e., medical home).
  • How to determine attribution of patients to a physician practice.

Geographic Practice Cost Indices (GPCIs)

CMS updates the GPCIs every 3 years. CMS did not propose any GPCI changes in he current proposed rule, as the next GPCI update will be in 2014.

Multiple Procedure Payment Reduction

CMS would apply a 25% multiple procedure payment reduction to the technical component of diagnostic cardiovascular and ophthalmology services when these services are furnished by the same physician (or physicians in the same practice) to the same patient on the same day.

Certified Registered Nurse Anesthetists and Chronic Pain Management Services

CRNAs could furnish and receive Medicare payment for chronic/interventional pain management and any other medical or surgical services “related to anesthesia” as long as such services are authorized by state law.

Elimination of Requirement to Terminate Prepayment Medical Review

The current one-year limit on non-random prepayment medical review would be removed.

Face-to-Face Requirement for Durable Medical Equipment

ACA requires that a physician have an in-person encounter with a beneficiary during the six-month period prior to a written order for certain Medicare-covered durable medical equipment. CMS proposes to reduce the requirement to no more than 90 days before the order is written or within 30 days after the order is written.

For details regarding the estimated impact of provisions in the Medicare physician fee schedule proposed rule for 2013, click here for the impact tables.

Source: American Medical Association



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