CMS Releases Proposed Rule for 2017 Medicare Physician Fee Schedule

The Centers for Medicare and Medicaid Services (CMS) released its proposed rule for the CY2017 Medicare Physician Fee Schedule (PFS). ASA will closely analyze the 856-page rule and prepare comments in response. 

Issues and proposals that are important to ASA members include: 

Forecasted Conversion Factor (subject to change in final rule)
Anesthesia: Conversion Factor declines from $21.9935 for 2016 to $21.9756 for 2017
RBRVS: Conversion Factor declines from $35.8043 for 2016 to $35.7751 for 2017
Both Conversion Factors include the 0.5% increase from MACRA but that increase was subsumed by other required adjustments (budget neutrality and multiple procedure payment reduction (MPPR) for imaging) 

Anesthesia for GI Endoscopy (Codes 00740 and 00810)
At the urging of ASA, CMS proposes to maintain the current value of 5 base units for 2017. CMS stated, “We agree that it is premature to propose any changes to the valuation of CPT codes 00740 and 00810 but continue to believe that these services are potentially misvalued and look forward to receiving input from interested parties and specialty societies for consideration during further notice and comment period.”  ASA met with CMS in Baltimore to urge them to keep the codes’ current values until new codes could be developed to distinguish between screening endoscopy and diagnostic and therapeutic endoscopies.

Interlaminar Epidurals
In response to the work of the ASA and other pain-related specialties, CMS proposes to stabilize payments for interlaminar epidurals. CMS proposed to accept the RUC recommendation for eight (8) new codes that will replace current codes 62310, 62311, 62318 and 62319. CMS called these codes out as potentially misvalued back in 2012.  The original codes were re-valued for CY2014 – and those values represented drastic reductions.  After much advocacy work by ASA and other specialties whose members perform these services, CMS agreed to revert back to the original work values for CY2015 with the caveat that it would not allow separate reporting of any associated imaging. CMS also placed these codes back on its list of potentially misvalued services with a request for the specialties to address concerns about the use of imaging associated with these procedures.  As proposed, these new codes will become effective next year and the values, if finalized, would recapture what had been lost in 2014.

Quality Reporting
In general, the proposed PFS primarily seeks to align certain features of quality measurement and use of electronic health records with recent Medicare Access and CHIP Reauthorization Act (MACRA) proposals. The proposals also provide additional clarification for quality measures reportable under Accountable Care Organization options for PQRS and assessment under the value-based payment modifier. Of note, CMS expects to release their analysis of the impact of the VBM for 2017 (based upon data submitted in 2015) on the number of groups and physician solo practitioners what will be subject to the VBM.

The proposed rule is available at https://www.federalregister.gov/articles/2016/07/15/2016-16097/medicare-program-payment-policies-under-the-physician-fee-schedule-medicare-advantage-pricing-data