“Shock and Awe:” The 2019 MPFS

CMS released the MPFS on Nov. 1, ending months of turmoil.

The Centers for Medicaid & Medicare Services (CMS) released the final rule on the Medicare Physician Fee Schedule (MPFS) and the Quality Payment Program (QPP) on Nov. 1. The 2,378-page document is available in the Federal Register. This marks the end of a tumultuous few months for the medical community, since the proposal was released in July.

“The historic reforms CMS finalized today move us closer to a healthcare system that delivers better care for Americans at lower cost,” said Alex Azar, the U.S. Department of Health and Human Services (HHS) Secretary.

“Today’s rule finalizes dramatic improvements for clinicians and patients and reflects extensive input from the medical community,” added CMS Administrator Seema Verma. According to Verma, the rule will address onerous documentation requirements, allowing physicians to spend more time with their patients, and also will focus on physician burnout.

The CMS press release on this topic touts the rule as the first attempt from the agency to bring sweeping changes to evaluation and management (E&M) services, which have not been updated in 20 years. The release also mentions CMS’s attempt to reimburse physicians for technology-based virtual care, President Trump’s commitment to lowering prescription drug costs, and a major overhaul to electronic health record (EHR) requirements to promote inter-operability.

On the same evening as the press release’s distribution, an American Medical Association (AMA) press release applauded CMS for addressing the problem of regulatory burdens on physicians, especially eliminating the need to re-document certain redundant information during follow-up visits. AMA also supported CMS for delaying the proposed collapsing of E&M codes.

If you had read my post immediately following the release of the proposal back in August, I voiced concerns regarding having a single code for follow-up visits, as well as about lifting the documentation requirements. These two moves would put geriatricians, and those working in similar specialties that tend to spend a lot of time with patients during office visits, at a huge disadvantage. It also will lead to the likelihood of increased fraud and non-medically necessary visits.

Medical societies worked day and night to register their comments before the Sept. 10 deadline. Most of them opposed immediate adoption of the proposal to collapse the E&M codes, so CMS granted them their wish; this will not be finalized until 2021.

This rule does lift the redundant requirements for attending physician re-writing information that was already collected and entered by office staff or by residents or fellows. The rule also eliminates the requirement of documenting medical necessity of home visits in lieu of office visits.

The final 2019 MPFS conversion factor is $36.04, which is a small increase from the 2018 value of $35.99.

The rule also finalizes two new codes for brief communication technology-based service and remote evaluation of recorded video and/or images.

On the Accountable Care Organization (ACO) side of things, the rule implements a voluntary six-month extension for existing ACOs, as well as allows attribution of patients that see a nurse practitioner, physician assistant, certified nurse specialist, or a physician with a specialty not associated with previous assignment methodology.

On the Quality Payment Program (QPP) side of things, the major changes are on advancing care information (ACI) as it morphs into promoting interoperability (PI). There is also an ongoing attempt to incentivize small practices to report into the Merit-Based Incentive Payment System (MIPS).

In conclusion, the jury is still out in the broader physician community as to whether they like this new rule. Social media is lighting up with knee-jerk reactions, and so far, the “yeas” and “nays” are running neck-and-neck.

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