A quick look at the 2017 proposed Medicare Fee Schedule

July 12, 2016

DSC_9174-051111The Centers for Medicare and Medicaid Services is aiming to better compensate primary care physicians for helping to coordinate their patient’s care and for providing behavioral health services, according to the agency’s proposed 2017 fee schedule that was released late last week.

The latest proposal aims to raise payments for physicians assisting patients with care coordination and planning, care for cognitive disabilities and overall mental health care. Providers would also receive increased compensation for providing care to patients with mobility-related impairments due to the increased attention and time commitment these patients often require, which falls in line with the ongoing push toward value-based care being spurred by MACRA.

While pathology labs and practices don’t stand to face any drastic changes most weren’t previously aware of, there are at least a few key items to note:

  • The standard times established last year for six clinical labor services will remain the same. An additional 11 could also be standardized pending forthcoming recommendations from RUC. See the figure below.
Credit: Centers for Medicare and Medicaid Services

Credit: Centers for Medicare and Medicaid Services

  • A number of CPT codes have also undergone slight work RVU modifications. Click here to see a full list starting on page 374. (Use the “ctrl F” search function on your keyboard to search for a specific code without scrolling.)

Additionally, a couple key pathology-related proposals were also put forth by CMS as part of an effort to amend the hospital outpatient prospective payment system.

  • A proposal to discontinue the use of the “L1” modifier on outpatient lab tests to identify unrelated tests on claims. These would instead be packaged if they appear on a claim with other hospital outpatient services.
  • A proposal to expand lab packaging exclusion that currently applies to molecular tests to all lab tests designated as an ADLT that meet established criteria. CMS also noted that it believes some of these diagnostic tests that meet the criteria will not be molecular tests, but will also have a different pattern of clinical use than more conventional tests, which in turn may make them less tied to a primary service in the hospital outpatient setting than more common and routine lab tests that are packaged. An “A” status indicator would be assign to ADLTs once a test is designated an ADLT under the clinical laboratory fee schedule.

Those pathology-specific adjustments aside, one of the most unique fee schedule proposals put forth is to expand the pilot Diabetes Prevention Program beginning Jan. 1, 2018. This would be the first time a preventative service program from CMS’ Innovation Center would be expanded into Medicare.

CMS projects these moves will generate a substantial funding boost, according to acting administrator Andy Slavitt.

“We conservatively estimate that these changes would result in approximately $900 million in additional funding in 2017 to physicians and practitioners providing these services,” Slavitt said on the CMS Blog. “Over time, if the practitioners qualified to provide these services were to fully provide these services to all eligible beneficiaries, the increase could be as much as $5 billion in additional funding for care coordination and patient-centered care.”

CMS is also proposing to add a provision that would reduce outpatient prospective payment system spending by roughly $500 million in 2017 by no longer paying for services at an outpatient department at a higher rate.

Besides physicians, the proposed fee schedule also pays nurse practitioners, physician assistants, physical therapists, in addition to radiation therapy centers and independent diagnostic testing facilities.

A new code has also been proposed to pay for cognitive and functional assessment and care planning for patients with cognitive impairment, such as for patients with Alzheimer’s.

Changes to payment for chronic care management, including payment for new codes and for extra care management provided by a physician or practitioner following the first visit for patients with multiple chronic conditions, were also proposed.

And in an attempt to keep with the times, there are three services CMS put forth to be added to the list a physician can offer through videoconference (dubbed telehealth). These new services would include critical care consultations, advance-care planning and some dialysis-related services for patients with end-stage renal disease.

CMS said the majority of these moves were made to respond to concerns raised by physicians regarding pain management, help focus payments on patients instead of setting, better utilize technology to improve patient care and to emphasize health outcomes important to patients.

Public comments on the proposed fee schedule can be submitted until Sept. 6.

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