AAFP responds to proposed rule on 2013 Medicare physician fee schedule
On Aug. 22, 2012, the American Academy of Family Physicians (AAFP) responded to the proposed rule on the 2013 Medicare physician fee schedule. As promised, I am sharing that response with you. Here are some of the highlights; the AAFP:
- Supports the Centers for Medicare & Medicaid Services' (CMS) proposal to create a code for post-discharge transitional care management as a short-term payment strategy; however, the AAFP urges CMS to limit the use of the code to the patient's primary care physician,
- Supports CMS’s intent to investigate potentially misvalued codes, especially in regard to the number and level of post-operative evaluation and management services assumed to be included in global surgical services,
- Urges CMS to not implement the Institute of Medicine recommendations pertaining to geographic practice cost indices, and instead asks that CMS refocus it's efforts on ensuring a properly distributed healthcare workforce that is meeting the demands of a growing beneficiary population,
- Agrees with the proposal to add coverage of ‘‘additional preventive services’’ and supports the proposal to add them to the list of Medicare telehealth services for 2013; however, the AAFP questions several of the proposed payment amounts for these services,
- Supports the CMS proposal to create new criteria for being a successful electronic prescriber for groups of two to 24 eligible professionals,
- Strongly supports CMS’s proposal to streamline the implementation of the Physician Quality Reporting System incentive and reporting programs within the context of the Medicare Shared Saving Program,
- Mostly supports the CMS proposal to begin applying the value-based payment modifier only to groups of 25 or more eligible providers in 2015, so the agency can begin learning how to properly fulfill the statutory requirements; however, the AAFP remains concerned with CMS’s inability to specify the exact amount of the upward payment adjustment because of budget neutrality considerations,
- Fully supports the agency’s proposal to begin Medicare Part B coverage of the Hepatitis B vaccine for high-risk groups, specifically persons with diabetes.
The full text of the AAFP response is available online.
The comment period for the proposed rule ends on Sep. 4, 2012. After that deadline, we will have to wait for the final rule to see what CMS decides to do on all of these issues. CMS is expected to release the final rule on the 2013 Medicare physician fee schedule on or around Nov. 1, 2012.
It's official: ICD-10 delayed to Oct. 1, 2014
Department of Health and Human Services (HHS) Secretary Kathleen Sebelius made official a one-year delay in the implementation deadline for the ICD-10 diagnosis code set when she announced last Friday a final rule that sets the new compliance date at Oct. 1, 2014. The delay, which was the subject of a proposed rule last April, is part of a final rule that will establish a unique health plan identifier, which HHS promises will "help cut red tape in the health care system." More to come on the HPID, as it's referred to. In the meantime, check out FPM's ongoing series of articles on ICD-10.
Medicare physician fee schedule redux
In a previous blog, I posted about the proposed rule on the 2013 Medicare physician fee schedule. I subsequently received questions regarding whether or not the American Academy of Family Physicians (AAFP) had any involvement in the creation of the proposed 2013 fee schedule and what impact the fee schedule might have on family physicians. To the best of my knowledge, AAFP was not directly involved in the creation of the proposed 2013 Medicare physician fee schedule. The Centers for Medicare & Medicaid Services (CMS) essentially reserves sole responsibility for its creation.
AAFP advocates with CMS throughout the year on elements of the physician fee schedule, and the results of that advocacy can be seen in CMS's estimate of the proposed rule's impact on family medicine. Specifically, CMS estimates that family physicians will experience approximately a 7 percent increase in Medicare allowed charges in 2013, based on what is in the proposed rule (see page 12 of the AAFP's summary of the proposed rule). That percentage is higher than any other specialty listed. So, although AAFP can't take responsibility for creating the proposed rule, it can certainly take some credit for the estimated positive impact on family physicians.
AAFP is preparing a response to
the proposed rule in advance of the Sep. 4, 2012, deadline for comments, and I look forward to sharing that with you in a future post. In the meantime, thanks for the questions, and please let me know if you have more.
Coming attractions: Medicare physician fee schedule
One of my favorite things about going to the movies is watching the "trailers" or "previews" that precede the main feature. I enjoy the glimpses of things to come and the anticipation that they foster.
Last week, the Centers for Medicare & Medicaid Services (CMS) offered a preview of the 2013 Medicare physician fee schedule in the form of a notice of proposed rule making (NPRM) published in the Federal Register. You can download a copy of the NPRM and view related links on the CMS website. The AAFP has provided a summary of the 341-page document.
As usual, the proposed rule for next year's fee schedule is full of interesting payment policy proposals. From a family medicine perspective, the most interesting one is a proposal to create and pay for a code that community physicians may report when they manage the care of a patient who is transitioning from a facility to an ambulatory, outpatient setting (e.g., from the hospital back to the community). CMS recognizes that a lot of expensive re-admissions could be prevented if transitions of care were better managed, and CMS appears willing to pay community physicians, including family physicians, for doing just that. CMS estimates that this proposal alone will increase Medicare allowed charges to family physicians by 5 percent in 2013.
Of course, not everything related to the Medicare physician fee schedule is good news. CMS separately estimates that, under current law, the physician fee schedule conversion factor will decrease 27 percent on Jan. 1, 2013, unless Congress and the President again intervene in the process.
CMS is accepting comments on its proposed rule until Sep. 4, 2012, so if you want to provide any feedback that may help shape the final product, you will need to submit it between now and then. Options for how to submit comments are included in an early section of the NPRM.
CMS plans to publish the final rule on or about Nov. 1, 2012, with implementation effective Jan. 1, 2013. Think of it as "show time" for the 2013 Medicare physician fee schedule. Here's hoping that the final product is more of an uplifting picture than any sort of comedy or horror show.