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On Thursday, July 3, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2015 Medicare physician fee schedule proposed rule. This proposed rule outlines proposed changes to policies and payment rates for services rendered on and after January 1, 2015.
In this rule, CMS proposes to revert back to the 2013 values that resulted from the ASA-led survey of codes for interlaminar epidural injections (CPT codes 62310, 62311, 62318 and 62319) for CY 2015. Additionally, CMS believes it appropriate that any imaging guidance be bundled into the injection codes and proposes to prohibit separate billing of imaging guidance in conjunction with codes 62310, 62311, 62318 and 62319. CMS proposes to include codes 62310, 62311, 62318 and 62319 on its potentially misvalued code list so that CMS can obtain information to support their valuation with the image guidance included.
The impact of all proposed RVU changes for anesthesia is zero percent and positive 1 percent for interventional pain (see table 60).
Beginning in 2015, a downward payment adjustment will apply to eligible professionals (EPs) who do not satisfactorily report data on quality measures for covered professional services or satisfactorily participate in a Qualified Clinical Data Registries (QCDR) such as the Anesthesia Quality Institute's (AQI) National Anesthesia Clinical Outcomes Registry (NACOR). CMS proposes to add 28 new individual measures and two measures groups to PQRS reporting. Additionally, CMS proposes to remove 73 measures, including PQRS Measure30 -Perioperative Care: Timing of Prophylactic Antibiotic—Administering Physician. EPs may still report measure 30 via AQI’s NACOR, a CMS-approved Qualified Clinical Data Registry (QCDR) (see table 24).
CMS also proposes that EPs who see at least one Medicare patient in a face-to-face encounter report measures from a newly proposed cross-cutting measures set in addition to any other measures that the eligible professional is required to report.
ASA leadership and staff are currently reviewing the proposed rule for matters specific to anesthesia and pain medicine and we will post more updates once that analysis is complete.
The comment period on the proposed rule is open for 60 days from the date it is published in the Federal Register. ASA will be formulating and submitting an official response.
