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The Centers for Medicare & Medicaid Services (CMS) has issued the attached proposed rule updating the physician fee schedule (PFS) for calendar year (CY) 2018. The proposed rule includes a number of provisions that will impact hospitals, including a proposal to reduce payments to non-excepted, off-campus provider-based departments to 25 percent, rather than 50 percent, of the outpatient prospective payment system (OPPS) rates. That provision is described in more detail in CHA’s overview of the CY 2018 OPPS proposed rule. Under the PFS, CMS proposes a total increase in payment rates of 0.31 percent for CY 2018, which includes a 0.5 percent update as required by the Medicare Access and CHIP Reauthorization Act 2015, adjusted for a misvalued code as required under the Achieving a Better Life Experience Act of 2014.
Other provisions that will impact hospitals are:
- Telehealth Services: CMS proposes to add a number of codes to the list of Medicare-payable telehealth services, including psychotherapy for crisis, health risk assessments, care planning for chronic care management, interactive complexity and counseling visits to determine low dose computed tomography eligibility.
- Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging: As required by the Protecting Access to Medicare Act (PAMA) of 2014, CMS continues its phased approach to implementing requirements that promote consultation of AUC for advanced diagnostic imaging services. CHA proposed that reporting requirements begin on Jan. 1, 2019; however, the agency proposes that 2019 will be an “educational and operations testing year,” and will pay claims regardless of whether they contain the required information on AUC consultation. CMS also proposes to implement a six-month voluntary reporting period beginning in July 2018 and seeks comments from stakeholders on the current readiness to meet the AUC requirements.
- Clinical Laboratory Fee Schedule (CLFS): As required by PAMA, CMS finalized extensive revisions to the Medicare payment, coding and coverage for clinical diagnostic laboratory tests paid under the CLFS. CMS now seeks comments from applicable laboratories and reporting entities about their experience with the first data collection and reporting periods to inform potential refinements to the CLFS for future data collection and reporting periods. CHA urges any members with applicable laboratories to contact us with their experience in reporting the required data, to inform CHA’s comment letter.
- Medicare Shared Savings Program (MSSP): CMS proposes to revise its beneficiary assignment methodology to include the utilization of services furnished by rural health clinics (RHCs) or federally qualified health centers (FQHCs), as required by the 21st Century Cures Act. In addition, CMS proposes to streamline certain documentation and certification requirements for the MSSP program application and the application for Track 3 Accountable Care Organizations seeking a waiver of the skilled-nursing facility three-day stay rule.
- Care Coordination by RHCs and FQHCs: CMS proposes to establish payment for regular and complex chronic care management services, general behavioral health integration services and psychiatric collaborative care model services provided by RHCs and FQHCs. This payment would be in addition to the payment for an RHC or FQHC visit.
The proposed rule also requests feedback on ways to better achieve transparency, flexibility, program simplification and innovation to inform possible future regulatory action related to the PFS. CMS is soliciting specific recommendations for regulatory, sub-regulatory, policy, practice and procedural changes to achieve these goals.
CHA is currently analyzing this proposed rule and developing DataSuite analysis. In addition, CHA will host a member forum on Aug. 31 from noon – 1:30 p.m. (PT) to discuss the payment and quality provisions related to the OPPS, as well as the PFS provisions related to non-excepted, outpatient provider-based departments. Additional information, including online registration for the member forum and CHA’s detailed summary, will follow in the coming weeks. Comments on the proposed rule are due Sept. 11.
