CMS Releases Medicare Physician Fee Schedule Proposed Payment Rule for CY 2016
On Wednesday, July 8, 2015, the Centers for Medicare and Medicaid Services (CMS) posted the Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule and Other Revisions to Part B for CY 2016 Proposed Rule. The proposal addresses changes and updates to Medicare Part B payment policies, payment rates, and quality provisions for services provided under the Medicare Physician Fee Schedule (MPFS). The proposed changes will be codified in a final rule in early November 2015 and implemented on or after January 1, 2016. The proposed rule is open for comment through September 8, 2015, and the Academy will be submitting a detailed comment letter prior to the deadline.
This is the first MPFS proposed rule since the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) in April 2015, which effectively repealed the flawed sustainable growth rate (SGR) formula. This legislation also set forth a new payment system for providers known as the Merit-Based Incentive Payment System (MIPS). CMS has begun the implementation of the MIPS in this proposed rule. The Academy will be analyzing these proposed changes for their impact on the profession of audiology.
CMS estimates the 2016 conversion factor (CF) to be $36.1096. This number includes the 0.5% payment update specified under MARCA. This CF is used to calculate the MPFS reimbursement rates.
Proposed Values for Two New Vestibular Codes
CMS has published the proposed values for two new caloric irrigation codes. These two new codes are designed to replace CPT code 92543. The publication of proposed values for the upcoming calendar year (CY) marks a change in process adopted in the CY 2015 final rule. Proposed values for most codes that are being valued in the upcoming CY will be published in that year's MPFS proposed rule. For example, codes that are being valued for CY 2016 have been published in the CY 2016 MPFS proposed rule instead of in the final rule as they were in years past. The Academy is reviewing the proposed values for the two new caloric codes and will offer comments to CMS. The Academy will also provide guidance to its members regarding the two new codes as we approach the January 1, 2016 implementation date.
Audiology Codes Identified as Potentially Misvalued Services
CMS has identified two audiology-related codes as potentially misvalued services. These codes include CPT code 92557 (Comprehensive audiometry threshold evaluation and speech recognition) and CPT code 92567 (Tympanometry). These codes were identified by CMS through a high expenditure by specialty screen. The Academy will review next steps in addressing these codes.
Physician Quality Reporting System (PQRS)
The Academy is in the process of reviewing the PQRS provisions in the proposed rule. Upon initial review, it appears there are no changes in measures for audiologists. The Academy will continue to update its members as they further review and analyze the PQRS provisions found in the MPFS proposed rule for CY 2016. Click here for more information on current PQRS reporting requirements.
The Academy's Quality Measures Subcommittee (QMS), along with the AQC, will continue to work diligently to develop additional discipline-specific quality measures for the profession of audiology.
Definition of satisfactory reporting/satisfactory participating
In the proposed rule, CMS states that they have finalized the criteria for satisfactory reporting for the submission of individual quality measures via claims and registry. For the applicable (12 month) reporting period, eligible providers would have to report at least 9 measures covering at least 3 of the NQS domains, or if less than 9 measures apply to the eligible provider, report on each measure that is applicable and report each measure for at least 50 percent of the Medicare patient visits during the reporting period to which the measure applies.
The profession of audiology continues to be impacted by the increase in reporting requirements in 2014 from 3 measures to 9 measures covering at least 3 of the National Quality Strategy (NQS) domains. In the past, the Academy has urged CMS to continue the use of the Measure-Applicability Validation (MAV) process as a method for audiologists to report on PQRS measures and avoid the 2% payment penalty when current circumstances requires they report on fewer than 9 measures. In the MPFS proposed rule, CMS states that eligible professionals who report on 1-8 measures would still be subject to the MAV process.
Future of PQRS
It is also important to note that the passage of MACRA authorized the end of the PQRS in 2018 and a beginning of a new program, the MIPS. The MIPS will likely incorporate aspects of the PQRS program. In the proposed rule, CMS notes that the 2018 PQRS payment adjustment will be the last adjustment issued under the PQRS. Future payment adjustments will be made under the MIPS as outlined by MACRA. The Academy will review further and provide comments to CMS related to the MACRA provisions in the proposed rule.