Overview of the 2019 Medicare Physician Fee Schedule (MPFS) Proposed Rule

Practices should consider making comments on the MPFS Proposed Rule as it may impact your practice significantly. The proposed rule is available under the PDF link here. Comments are due by Monday, September 10 at 5:00 pm ET and can be made here.                
 
Highlights of the rule include:
 
  • Conversion Factor – proposed amount is $36.05, up from $35.99. 
  • Consideration of Opioid Bundles - CMS is asking for comments on creating a bundled episode for substance abuse disorders and identify non-opioid alternatives for pain management
  • Mis-valued Codes Initiative - codes being revalued, some to the detriment of practices, as well as high cost procedures (especially for orthopedic procedures – pages 101-102 of the proposed rule)
  • E-visits - Small reimbursement for e-visits to reduce overall reimbursement in the MPFS
  • Changes to MIPS – combining the MPFS and QPP updates
  • Adding EHR utilization performance to the Physician Compare Tool on CMS’ QPP website
  • Many changes to Virtual Care – CMS wants providers to use telecommunications technologies, and the proposed rule contains new codes for additional remote patient monitoring and virtual check-in (calling over telephone, etc.). Looking to provide separate payment when patients send video or images to provider (for wound care, etc.), and interprofessional internet consultations (consulting with other providers like specialists).
  • Chronic care management – new code being considered
  • Price Transparency – patients are negatively impacted by surprise bills or out of network balance billing. CMS is considering ways to improve accessibility and usability of current charge information. They may require providers to post all charges that patients can review prior to treatment. This could impact workload – and may eventually influence private payers to require the same.
  • Part B New Drugs – only on newly released drugs, CMS is considering reducing the initial wholesale acquisition cost (WAC) add on payment to 3% from 6%.
 
This information was taken from an InfoDive webinar on July 25, 2018 on the 2019 MPFS Proposed Rule. A follow-up article on proposed changes to Evaluation and Management Codes will be published shortly.