A familiar tune
The end-of-year holiday season is upon us. I can always tell it is because of the displays in the stores, the songs on my radio, and the phone calls I receive asking about the status of next year's Medicare physician fee schedule.
Each year about this time, I start getting phone calls from anxious physicians and their staff members asking if the Medicare fees really are going down in January or whether Congress will intervene as it has in the past. This year is no different. Under current law, the Medicare conversion factor (which converts relative value units (RVUs) to Medicare payment allowances) is scheduled to decrease by approximately 21 percent for services provided on or after Jan. 1, 2010. That decrease will be partially offset by RVU increases announced for office visits and other evaluation and management services that family physicians frequently perform, but Medicare fees will still decline significantly if the conversion factor goes down.
For the past several years, Congress has intervened at the last minute (or sometimes after the last minute) to either freeze the conversion factor or increase it slightly (although the increase is always less than the rate of inflation, so physicians still lose). The expectation and hope is that Congress will do so again this time around. For instance, as I write this, the U.S. House of Representatives' Rules Committee has produced a Defense appropriations bill that includes, among other things, a provision to extend the current Medicare physician payment rates through the end of February, with the expectation that this extension will give Congress enough time to enact health reform legislation that includes a longer-term fix to Medicare's Sustainable Growth Rate (SGR) and physician fee schedule issue. It's probably appropriate that the extension is attached to a Defense appropriations bill, since physicians would likely be up in arms if Medicare rates actually fell 21 percent.
In the meantime, the fact remains that Medicare fees will drop in January unless Congress intervenes, which it has not completely done yet. So, what's a physician to do? Well, the good folks at the Centers for Medicare and Medicaid Services have given you until Jan. 31, 2010 to decide. That's when the current period for changing your Medicare participation status for 2010 will end. For more information, I would encourage you to visit the Medicare participation options web page on the American Academy of Family Physicians' web site.
And with that, I'll return to listening to the radio, where I can almost hear the Congressional Tabernacle Choir singing:
God rest ye merry gentlefolk; let nothing you dismay.
We plan to patch the SGR, and not to cut your pay.
Then do it all again next year, lest you should go astray.
So our tidings of comfort to the annoyed, to the annoyed.
So our tidings of comfort to the annoyed!
CMS issues a temporary cease fire
As a follow-up to my last posting ("Medicare shoots first and asks questions later," Nov. 19), I wanted to let readers know that the Centers for Medicare and Medicaid Services (CMS) announced on Nov. 23 that it would delay implementation of new rules that give Medicare the authority to reject claims for services or supplies when the ordering physician or health care professional is not enrolled in the Medicare Provider Enrollment, Chain, and Ownership System, or PECOS. The agency is delaying implementation of the new policy until April 5, 2010. According to CMS, an extension of the implementation date will give physicians and other health care providers sufficient time to enroll or, if necessary, re-enroll in Medicare. CMS has indicated that more detailed information about the rules delay will be published soon in MLN Matters, an online publication that is part of CMS's Medicare Learning Network.
Interestingly, CMS's announcement came just a week after the American Academy of Family Physicians, the American Medical Association, and more than 50 other medical organizations sent a letter to CMS Acting Administrator Charlene Frizzera expressing concerns about the policy. Among other things, the letter asked for an indefinite suspension of CMS's plans. While April 5 does not constitute an "indefinite" suspension, it does suggest that CMS is listening and that collective advocacy on the part of organized medicine can have an impact. When it comes to Medicare, one must take comfort where one can find it.
So, if you or other health care professionals who refer to you are not yet in PECOS, you have been granted a reprieve. Just remember that a reprieve is not a pardon, and CMS will resume shooting on April 5, 2010. In the meantime, to quote an old adage, "Forewarned is forearmed."
2012 will be here sooner than you think
With the business of today to handle, preparing for a change you must accommodate by Jan. 1, 2012 may not seem a high priority. However, the change to the 5010 version of the HIPAA-compliant electronic transaction standards that must be used as of Jan. 1, 2012 will likely require quite a bit of advanced planning, and 2010 is a good time to start. There will be many steps in the process, many of which will require working with software and hardware support vendors, clearinghouses and payers to upgrade systems and conduct testing.
Every entity that sends or receives electronic transactions such as claims submissions, eligibility inquiries, claims acknowledgments and reports must upgrade to the new standards. So, unless you are lucky enough to be one of the biggest customers of your software and hardware support vendors or have persons internally who provide these services, you may want to start vying for attention early.
To help with your planning, the AAFP has put together a checklist that may help you identify the tasks to be performed and create your 5010 transition plan. The checklist provides an example of the steps that may be needed to coordinate upgrades and testing, recognize and plan for expenditures and process changes, and verify successful transmission. Also included are a list of electronic transactions included in the 5010 standard and potential questions to discuss with software vendors/system support staff.
An added benefit of planning now for the transition to the 5010 standards is that implementing them is preparation for the Oct. 1, 2013 adoption of the ICD-10-CM diagnosis code set. The new standards will provide the identifiers necessary for transmission of the ICD-10 codes. Discussions with software vendors about the 5010 transition should also include initial inquiries about the vendors' plans and progress toward an ICD-10 upgrade.
Time flies whether you are having fun or not. Hopefully some early planning and preparation for change will allow for easier transitions and more time for the fun stuff.