CMS has released the 2016 Medicare Physician Fee Schedule (MPFS). This major, proposed rule will revise payment polices under the Medicare Physician Fee Schedule (PFS) and make other policy changes related to Medicare Part B payment. The 815 page key payment legislation is part of a broad effort to move Medicare toward value-based, quality care and is the first proposed update to the physician payment schedule since the repeal of the Sustainable Growth Rate through the Medicare Access and CHIP Reauthorization Act of 2105 (MACRA). The rule, called CY 2016 Physician Fee Schedule, is expected to be published as a final rule this fall. The public has 60 days from the July 8, 2015 release of this rule to comment. The American College of Radiology said that it will continue discussions with CMS on behalf of radiologists and participating facilities.
Here are highlights of the proposed rule that will affect radiologists and entities who provide medical diagnostic imaging. Among the ramifications for providers of radiology services are:
1. Overall Impact Estimates
|
(A) Specialty |
(B) Allowed Charges (mil) |
(C) Impact of Work RVU Changes |
(D) Impact of PE RVU Changes |
(E) Impact of MP RVU Changes |
(F) Combined Impact** |
|
Diagnostic Testing Facility. |
$719 |
0% |
1% |
0% |
1% |
|
Interventional Radiology. |
$296 |
0% |
1% |
0% |
1% |
|
Portable X-Ray Supplier. |
$103 |
0% |
0% |
0% |
0% |
|
Radiation Oncology. |
$1,769 |
0% |
-3% |
0% |
-3% |
|
Radiology. |
$4,472 |
0% |
0% |
0% |
0% |
For a full listing of allowed charges and impact changes on all specialties, see pages 711 and 712 of the CY 2016 Physician Fee Rule.
2. Digital Practice Expense Inputs
On page 44 of the CY 2016 Rule, CMS proposes to update the price for the PACS workstation to $5,557 from the current price of $2,501 since the latter price was based on the proxy item and the former based on submitted invoices.
3. Appropriate Use Criteria/Clinical Decision Support
CMS gives this area quite a bit of attention – 17 pages worth. To read the text in its entirety, see pages 352-369 of the CY 2016 Rule. Highlights include:
- CMS proposing a development process to allow flexibility for provider-led entities.
- CMS setting standards including evidence-based development process and transparency.
- Acknowledgment by CMS of the provision within the Protecting Access to Medicare Act (PAMA) around relative value units (RVUs) and whether these services are not new or revised codes. CMS is proposing a two-phase reduction over two years with 19 percent reduction the first year and phasing in any remaining reduction greater than 19 percent in the second year rather than implementing a 50 percent of the reduction in each of the two years.
- PAMA mandates in Section 218(a)(1) that the technical component of applicable computed tomography services paid under the physician fee schedule and HOPPS will undergo a 5 percent reduction in 2016 and a 15 percent reduction in 2017; subsequent years by made for services furnished using equipment that does not meet the requirements of the NEMA Standard XR-29-2013.
- Beginning in 2016, claims for CT scans described by above-listed CPT codes (and any successor codes) that are furnished on non-NEMA Standard XR-29-2013-compliant CT scans will be required to include modifier “CT”, which will result in a payment reduction.
4. Radiation Oncology
Beginning on page 235, the ruling discusses Image Guidance Services. Radiation oncology will experience an adjustment for the equipment utilization rate assumption for the linear accelerator to account for a significant increase in usage. Instead of applying the 50 percent assumption, a 70% assumption is proposed, to be phased in over two years. Page 241 of CY 2016 Rule explains in detail how CMS arrived at the 70%.
MPFS Updates and Sources
For a link to the press release issued by CMS on the proposed CY 2016 Physician Fee Rule, click here.
For a link to the preliminary summary of the rule by ACR, click here.
For a link to the federal register that houses the PDF of the proposed rule, click here.
With the health care environment rapidly evolving on a regular basis, it is important to stay on top of industry trends and regulatory changes. Stay tuned to our blog for the latest MPFS updates and insights from our team of radiologists and physicists as to how these changes will impact radiology practices.