Tony Mira, Chairman and Chief Executive Officer of MiraMed
CMS’s 2019 Proposed Payment Rule: Highlights for Anesthesia and Pain Management Providers
The proposed Medicare Physician Fee Schedule for 2019 includes a slight increase in the anesthesia conversion factor as well as some changes to the Quality Payment Program and a significant overhaul of documentation requirements for Evaluation & Management services. CMS is accepting comments on the proposal until September 10, 2018.
The Centers for Medicare and Medicaid Services (CMS) released the proposed Physician Fee Schedule (PFS) for 2019 on July 12, 2018. This eAlert highlights aspects of the proposed rule with the greatest importance for anesthesia practitioners.
According to the proposal, the national conversion factor (CF) for anesthesia services (unadjusted for geographic practice cost differences) would see a slight increase in the next calendar year to $22.2986 from $22.1887 in 2018. As with the non-anesthesia PFS CF, (see below), these increases include the 0.25 percent positive adjustment and budget neutrality adjustment mandated by the Bipartisan Budget Act of 2018. The anesthesia CF also reflects additional anesthesia-specific adjustments for increases in resource costs related to practice expenses and malpractice insurance.*
The proposed Resource-Based Relative Value Scale (RBRVS) CF (non-anesthesia) of $36.043 for 2019 also represents a slight increase from the 2018 CF of $35.996. The RBRVS, based on recommendations from the American Medical Association/Specialty Society Relative Value Scale Update Committee (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. (Anesthesiologists would use this CF to bill for flat fee services, such as the use of ultrasound guidance in the placement of a nerve block.)
Significant changes to the Quality Payment Program (QPP) and a restructuring of coding and documentation requirements for Evaluation and Management (E&M) services to reduce administrative burden for clinicians are also among the proposal's highlights. In a statement, CMS Administrator Seema Verma hailed the 1,400-page document as the fulfillment of a promise by the agency "to put patients over paperwork by enabling doctors to spend more time with their patients." According to Ms. Verma, the proposals would streamline documentation requirements, enabling clinicians to be more productive and focus more on the delivery of care.
CPT code 95970 was identified as potentially misvalued. The chart below reflects CMS's proposed RVU for this code for 2019. CMS disagrees with the RUC's recommendation to keep the work RVU for the code at 0.45 and proposes a reduction to 0.35.
Source: CMS-1693-P, TABLE 13: CY 2019 Proposed Work RVUs for New, Revised, and Potentially Misvalued Codes
Evaluation & Management Restructuring
As part of its Patients Over Paperwork initiative to reduce the administrative burden for clinicians, CMS is proposing significant changes to the documentation and coding requirements for E&M services. These proposals are likely to have the greatest significance for chronic and interventional pain specialists.
"E&M visits make up 40 percent of all charges for Medicare physician payment, so changes to the documentation requirements for these codes would have wide-reaching impact," noted Ms. Verma in a July 17 letter to physicians.
The proposed overhaul would increase the options for documentation requirements from the 1995 and 1997 guidelines to also include the more liberal use of time and medical decision-making. The current payment differentials for levels 2-5 would be replaced with one payment level for office visits for new patients (CPT codes 99202-99205) and one payment level for established patients (CPT Codes 99212-99215).
"Most specialties would see changes in their overall Medicare payments in the range of 1-2 percent up or down from this policy, but we believe that any small negative payment adjustments would be outweighed by the significant reduction in the documentation burden," she said.
CMS also proposes restructuring E&M documentation and coding requirements to:
Quality Payment Program Changes
According to CMS, the proposed changes to the QPP also aim to reduce administrative burden, while focusing on outcomes and promoting the interoperability of electronic health records. For Year 3 of the QPP, CMS proposes, among other things, to:
For More Information
The complete 2019 proposed rule is available here.
A fact sheet on the proposed rule is available here.
A fact sheet on the proposed rule for Year 3 of the QPP is available here.
A press release on the proposed rule is available here.
CMS is accepting comments on the proposed rule until September 10, 2018. You can expect the final rule to be published in mid-November.
With best wishes,
President and CEO