Anesthesia Business Consultants

Weekly eAlerts Covering Regulatory Changes, Compliance Reminders &
Other Changes in the Anesthesia Industry

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Anesthesia Industry eAlerts

Sent to subscribers every Monday morning, our eAlerts deliver timely updates on regulatory, legislative and practice management developments of interest to anesthesia professionals.

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Summary
The national anesthesia conversion factor for the 2019 Physician Fee Schedule final rule increased minimally to $22.27 from $22.19 in 2018.  We review highlights of the 2019 rule with relevance for anesthesia providers, including changes to the Quality Payment Program for payment year 2021.  Significant changes in documentation requirements for E&M services were finalized for 2019. We are analyzing these changes and will discuss their implications for anesthesia practitioners in a future eAlert.

November 19, 2018

The Centers for Medicare and Medicaid Services (CMS) has published the 2019 Physician Fee Schedule (PFS) final rule detailing, among other things, how anesthesia practitioners will be paid in the coming year and how their participation in Year 3 of the Quality Payment Program (QPP) could impact their payment in 2021.

The national anesthesia conversion factor (CF) rose 0.27 percent to $22.27 from $22.19 in 2018, reflecting anesthesia-specific resource costs related to practice expenses and malpractice insurance. This CF represents the national average. The table here shows the 2018 and 2019 anesthesia CFs by location.*

The non-anesthesia CF also rose slightly from $35.99 to $36.04, representing a 0.25 percent adjustment as mandated by the Bipartisan Budget Act of 2018 as well as a negative 0.14 percent adjustment in keeping with the law’s budget neutrality requirements. Anesthesiologists would use this CF to bill for flat fee services, such as the use of ultrasound guidance and nerve block placement.

As proposed, the work relative value unit (RVU) (one of the three components used to determine fees) for CPT code 95970 (Electronic analysis of implanted neurostimulator pulse generator/transmitter) was reduced from 0.45 to 0.35 for 2019.

Some changes in documentation requirements for E&M services designed to ease administrative burden for clinicians will be implemented in 2019. We are analyzing these changes and will discuss them in a future eAlert. We will also discuss the implications for anesthesia and pain management providers of the significant expansion of payment for telehealth services that became policy with the final rule.

Quality Payment Program Changes

According to CMS, many of the changes to the QPP for the 2019 performance year (2021 payment year) also aim to reduce administrative burden while strengthening the focus on outcome over process measures.

Changes to the QPP for 2019 include:

  • Expanding the low-volume threshold criteria and giving clinicians who meet only one of the three criteria the option not to participate in the QPP’s Merit-Based Incentive Payment System (MIPS).  Eligible clinicians (ECs) who bill $90,000 or less in Medicare charges or who see 200 or fewer Medicare patients or bill 200 or fewer covered professional services may opt out of MIPS.
  • The opportunity for clinicians or groups to opt-in to MIPS if they meet one or two of the low-volume threshold criteria.
  • The removal of 21 MIPS Clinical Quality measures, including two measures (MIPS 426 and 427) related to transfer of care. CMS argued that removing the “extremely topped out” measures would help reduce reporting burden “where there is little room for improvement.” 
  • The requirement for eligible clinicians or groups to achieve 30 or more total MIPS points to avoid a negative payment adjustment of up to 7 percent in payment year 2021.
  • Allowing facility-based clinicians (those who provide 75 percent or more of their covered services in inpatient hospital, on-campus outpatient hospital or emergency room settings) to use the measure set for the Hospital Value-Based Purchasing Program (VBP) for their Quality and Cost scores.

The complete final rule is available here.

A fact sheet on the final rule is available here.

A fact sheet on the Quality Payment Program is available here.

With best wishes,

Tony Mira
President and CEO

* The Resource-Based Relative Value Scale (RBRVS), based on recommendations from the RUC, is designed to vary payment for physician services to reflect changes in the resource costs of providing those services in three areas:  physician work, practice expense and professional liability insurance. Using the RBRVS, Medicare determines the relative value units (RVUs) for each CPT code.  Under the PFS, each of the three resource elements is assigned an RVU for each CPT code.  The RVUs are then adjusted based on the geographic practice cost index (GPCI) for various areas of the country.  The conversion factor is multiplied by the total geographically adjusted RVU to determine the payment for a given medical service.