When CMS released its final 2017 Medicare physician fee schedule on Nov. 2, the AAFP responded with a quick acknowledgement and promised family physicians an in-depth look at the details and a written summary of the complex document.
That 15-page summary(15 page PDF), crafted by AAFP payment and policy experts, is now available.
The document is organized into topic areas that first give background information on CMS' initial proposals, then remind readers of the AAFP's recommendations following release of the proposed rule and, ultimately, follow with final rule decisions. Tables at the end of the summary give a clearer picture of some of the more complicated items.
New CPT Codes, Misvalued Codes, Telehealth Services
The Academy and family physicians have a vital interest in CMS' continuing efforts to promote primary care as foundational to the Medicare program. In the 2017 fee schedule, CMS finalized a number of coding and payment changes to better identify and value primary care, care management and cognitive services.
"CMS estimates these new codes will result in an estimated $140 million in additional funding in 2017 to physicians and practitioners providing these services," says the summary. If more beneficiaries receive services in the future, the payment support for care coordination and patient-centered care could increase to more than $4 billion.
- CMS released the final 2017 Medicare physician fee schedule on Nov. 2.
- Less than two weeks later, AAFP experts have created a 15-page summary to highlight for family physicians the most relevant items in the fee schedule.
- The summary includes information on new CPT codes, misvalued codes, telehealth services, the Medicare Diabetes Prevention Program expansion, appropriate use criteria for advanced diagnostic imaging and the Medicare Shared Savings Program.
When it came to potentially misvalued services, CMS fell short in its efforts to identify a 0.5 percent reduction in relative value units (RVUs) and therefore adjusted the 2017 overall physician update. That mandatory adjustment resulted in a 2017 conversion factor of $35.89, an increase of only 9 cents from the 2016 conversion factor.
"The AAFP is frustrated that CMS was unable or unwilling to identify the full 0.5 percent reduction in RVUs required in 2017," says the summary.
Regarding Medicare telehealth services, the AAFP supported -- and CMS finalized -- additions to the list of services eligible to patients via telehealth to include
- end-stage renal disease services related to dialysis,
- advanced care planning and
- critical care consultations using new Medicare G codes.
Medicare Diabetes Prevention Program Expansion
The final rule defines the Medicare Diabetes Prevention Program(www.cms.gov) as a "structured lifestyle intervention that includes dietary coaching, lifestyle intervention and moderate physical activity" that aims to prevent the onset of diabetes in patients classified as prediabetic.
The AAFP fully supported the expansion of the program beginning Jan. 1, 2018, as proposed by CMS.
In its 2017 fee schedule, CMS finalized policies such as criteria for beneficiary eligibility, supplier eligibility and enrollment. "Future rulemaking will address policies related to payment, virtual providers and other program integrity safeguards," says the summary.
Furthermore, CMS will complete recommendations for the payment structure of the expanded diabetes prevention program during 2017, and the agency expects to begin payment for the services in 2018.
Appropriate Use Criteria for Advanced Diagnostic Imaging
In 2014, Congress passed the Protecting Access to Medicare Act, which established a program to promote the use of appropriate use criteria for advanced diagnostic imaging services. The policy requires a physician to consider, when ordering certain imaging services, the criteria that apply to the imaging modality ordered for his or her Medicare patient.
The proposed physician fee schedule included, among other things, clinical decision-support mechanism requirements and exceptions for ordering professionals for whom consultation with appropriate use criteria would pose a "significant hardship."
The final rule defines the clinical-decision support mechanism as "the electronic tools through which a clinician consults appropriate use criteria to determine the level of clinical appropriateness … for that particular patient's clinical scenario." The final rule mandates that the mechanisms incorporate specified, applicable appropriate use criteria that cover the full clinical scope of all priority clinical areas, and finalized the first eight of these areas as
- coronary artery disease (suspected or diagnosed),
- suspected pulmonary embolism,
- headache (traumatic and nontraumatic),
- hip pain,
- low-back pain,
- shoulder pain (to include suspected rotator cuff injury),
- cancer of the lung (primary or metastatic, suspected or diagnosed) and
- cervical or neck pain.
Furthermore, CMS addressed specific requirements related to clinical decision support mechanism tools -- including setting a March 1, 2017, deadline for the first round of applications for those entities looking to qualify their electronic tools through which a physician would consult appropriate use criteria.
Medicare Shared Savings Program
The Medicare Shared Savings Program(www.cms.gov) was designed to increase coordination and cooperation among physicians and other health care providers to improve the quality of care and reduce unnecessary costs.
Physicians can participate in the program by creating or joining an accountable care organization (ACO).
The 2017 fee schedule finalized certain policies in the shared savings program. According to the AAFP summary, CMS indicated it would "incorporate new or revised beneficiary attestations and align such beneficiaries prospectively for all tracks at the beginning of each performance and benchmark year."
Furthermore, according to the summary, CMS noted its "intent to monitor the implementation of voluntary alignment" but warned that the voluntary alignment process was not intended as a way for ACOs to target patients who might help the ACO earn shared savings -- or as a mechanism for ACOs to avoid patients whose treatment by the ACO would be less likely to generate shared savings.
The AAFP included a number of other topics in its summary of the 2017 fee schedule, including
- updated geographic practice cost indices,
- zero-day global services typically billed with an evaluation and management code,
- Medicare Advantage (Part C) provider enrollment,
- the value-based payment modifier and
- the physician feedback program.
The final 2017 Medicare physician fee schedule is effective on Jan. 1, 2017.
Related AAFP News Coverage
AAFP Calls for Revisions in Proposed 2017 Physician Fee Schedule
CMS Proposal Signals Significant Boost in Primary Care Payment