Summary of 2015 Medicare Physician Fee Schedule (MPFS) Final Rule
On October 31st, 2014 CMS released final ruling on the 2015 Medicare Physician Fee Schedule (MPFS). This is a summary of that final rule.
- Accountable Care Organizations (ACOs) will see new quality measures with reduced reporting requirements and increased rewards for year-over-year improvements
In the proposed updates to MPFS, CMS had considered increasing the number of quality metrics used in Medicare Shared Savings Programs (MSSP) from 33 to 37. When making the final ruling CMS decided not to change the number of measures used, keeping it at 33.
However, CMS will create additional measures through claims while decreasing the number of measures that practices need to report through Group Practice Reporting Option (GPRO). This will effectively lower reporting requirements.
Furthermore, CMS will grant ACOs bonus points for year-over-year improvements (up to a determined maximum quality score). The potential for improvement-related bonus points was also increased from two to four points.
- Pay for Performance now applies to all, including ACO participants
There will be a raft of changes to the Medicare Value-Based Payment Modifier (VBPM) starting January 1, 2015. These are;
- VBPM will apply to all – starting 2017, all physicians will be required to participate in VBPM – including solo providers, physician groups comprising two or more Eligible Professionals (EPs), and any other provider who participates in Medicare ACOs such as MSSP, Pioneer, and CPCI.
- Non-physicians have an extra year to apply to VBPM – this group includes PAs and nurse practitioners, who now have until 2018 to apply.
- VBPM penalties will be doubled – penalties for eligible professionals who don’t participate in Physician Quality Reporting System (PQRS) or those who deliver low-quality care will increase from 2% in 2016 to 4% in 2017. Maximum bonuses for high-performers will increase from 2% to 4% in the same time frame.
- Reprieve for smallest groups – groups of less than 10 EPs that participate in PQRS will not face VBPM downward payment adjustments in 2017.
- Chronic Care management code reimbursement reduced
The proposed rule had put reimbursement at $41.92; the final rule has reduced this to $40.39. The new code can be billed for a patient once every 30 days for any care coordination work within the care period that lasted at least 20 minutes. Two other key proposals were finalized;
- Ease of delegating care – Physicians are now allowed to provide general supervision - as opposed to onsite oversight – for clinical staff who provide 20 or more hours of work per week.
- Every practice must use an Electronic Health Record (EHR) system – All physician practices, including radiology practices must use EHRs. One change evident in the final ruling is that the EHR doesn’t have to have been 2014-certified as initially proposed. The final rule says you can use any EHR system that was in use on 31st December of the previous year.
- Data to be collected on site
Following an increased need to better understand differences in practice costs, healthcare data will now be collected exactly where medical services are provided.
- Estimated payment impact lower than expected
Some specialty areas that had initially anticipated major Medicare payment changes will only be slightly impacted according to the Medicare final rule. These practices include independent labs, internal medicine, radiology, family practice, radiation oncology, and radiation therapy centers. Radiation in particular will see a -1 impact instead of the proposed -2.
You can find the complete MPFS changes on the Medicare website.
Healthcare Information Services (HIS) specializes in revenue cycle management for orthopedic and radiologic physicians, including everything from coding to collections.