UCAOA Offers Comments on Proposed Medicare Payment Policies
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UCAOA submitted comments  on September 6 to the Centers for Medicare and Medicaid Services (CMS) in response to the Calendar Year 2017 Medicare Physician Fee Schedule (PFS) Proposed Rule.  In its comments, UCAOA offered support of CMS’ proposal to modify the 24/7 access requirements for providers who want to bill Medicare for Chronic Care Management (CCM) codes.  In the proposed rule, CMS’ acknowledged that there is substantial local variation in how 24/7 access for urgent care needs are achieved, including contractual relationships between physician practices and other sites of service, including urgent care centers. CMS’ proposed changes would allow primary care providers to more easily meet the CCM billing requirements if they contract with urgent care centers for their patient’s acute care needs, including evenings and weekends.

Other topics on which UCAOA commented included:

  • 0-day Global Services that are Typically Billed with an Evaluation and Management Service with Modifier 25
  • Appropriate Use Criteria for Advanced Diagnostic Imaging Services
  • Establishing a HCPCS G-code to Improve Payment Accuracy for Care of People with Mobility-Related Disabilities
  • Addition of Services to the List of Telehealth Services for CY 2017
  • Non-Face-To-Face Prolonged Evaluation & Management Services

CMS is expected to publish the final rule on or about Nov. 1, 2016.

CMS Acting Director Pledges Flexibility with New Payment System Roll-Out

On Sept. 8, 2016, CMS Acting Administrator Andy Slavitt acknowledged the concerns expressed by the medical community and by lawmakers regarding the implementation timeline for the Medicare Access and CHIP Reauthorization Act (MACRA) and pledged that the final regulations will offer more flexibility for physicians.

MACRA, passed by Congress in 2015, repealed the Medicare sustainable growth rate physician payment formula and replaced it with a new payment system that represents a framework for rewarding providers for giving better care rather than more care. Physicians and other providers paid under the physician fee schedule can choose one of two paths to payment:  the Merit-Based Incentive Payment System (MIPS) or participation in an alternative payment model (APM). Fee schedule payments will be tied to this new system beginning in 2019, although the performance period starts next year.  
Final MACRA regulations are expected this fall.  Because there will be little transition time for physicians between publication of final regulations and the 2017 performance year, Administrator Slavitt announced that for 2017, CMS is going to allow physicians to “pick their pace” of transitioning to the new payment system. 

Physicians will be exempt from payment penalty in 2019 if they choose any one of the following four options:

  1. Submit some MIPS information, including data from after January 1, 2017.
  2. Submit MIPS information for a reduced number of days and potentially qualify for a small positive payment adjustment.
  3. Submit information for a full calendar year and potentially quality for a modest positive payment adjustment.
  4. Join an APM in 2017 and if enough Medicare payments or patients through the APM, qualify for a 5% incentive payment in 2019.

In June, UCAOA commented  to CMS on its proposed rule for implementing MACRA and in that letter stated that greater accommodations were needed for small practices, and, in particular for eligible clinicians who practice in urgent care centers, to successfully participate in MIPS.

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