On September 11, ACG, AGA and ASGE responded to major provisions proposed in the Centers for Medicare and Medicaid Services (CMS) calendar year (CY) 2018 Medicare Physician Fee Schedule (PFS) Proposed Rule and the CY 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System (ASC) Proposed Rule.
We anticipate that these rules will be finalized by early November.
Medicare Physician Fee Schedule
The Medicare PFS proposed rule includes proposals to update payment policies, rates, and quality provisions for services furnished under the PFS.
For CY 2018, CMS estimates there will be an across-the-board 0.19 percent reduction to PFS payments resulting from a failure to meet the misvalued code target of 0.5 percent in 2018. Despite this reduction, CMS estimates that the CY 2018 conversion factor will increase to $35.99 from $35.89 in CY 2017 based on the budget neutrality adjustment and the 0.5 percent update factor.
Our societies addressed several key provisions impacting GI in the CY 2018 Medicare PFS proposed rule. To read our comment letter on the proposed rule click here.
Anesthesia Services for Gastrointestinal (GI) Procedures
For CY 2018, CMS proposes to adopt the American Medical Association (AMA) Relative Value Scale Update Committee’s (RUC) recommended values for anesthesia services furnished in conjunction with, and in support of, gastrointestinal endoscopic procedures (Please note that the new values apply to anesthesia services only (e.g., monitored anesthesia care (MAC)), not moderate sedation.) Each base unit is approximately $22. The table below highlights the proposed changes to the base units of anesthesia services for GI procedures that the GI societies supported.
Evaluation & Management Guidelines and Care Management Services
Our societies support CMS’ proposed efforts to update the Evaluation and Management (E/M) documentation guidelines to reduce physician burden and to better align E/M documentation with the current practice of medicine. We encouraged CMS to focus E/M documentation requirements on the nature of the presenting problem, medical decision making and time with the patient. We support CMS’ recommendation to reduce documentation requirements related to history of present illness and physical exam.
Calculation of Malpractice RVUs
Our societies urged CMS not to implement proposed changes to lower the malpractice RVU for gastroenterologists in CY 2018. Instead, we recommended that CMS maintain the CY 2017 risk factors used to determine the RVU, which include unique non-surgical and surgical risk factors. Further, we urged CMS and its contractor to work with ACG, AGA and ASGE to better understand the data collected and to identify new sources that may be useful in improving its flawed dataset.
2018 Payment Adjustment for PQRS and EHR Incentive Payment Program
Our societies thanked CMS for recognizing that adjustments need to be made to the reporting criteria for the 2018 payment adjustment for the Physician Quality Reporting System (PQRS) and the Medicare Electronic Health Record (EHR) Incentive Program. For both programs, CMS proposed to reduce the 2016 quality reporting criteria from nine measures to six measures.
OPPS/ASC Payment System
This proposed rule describes the recommended changes to the amounts and factors used to determine the payment rates for Medicare services paid under the OPPS and ASC payment systems. Additionally, this proposed rule updates and refines the requirements for the Hospital Outpatient Quality Reporting (OQR) Program and the ASC Quality Reporting (ASCQR) Program.
To read our comment letter on the proposed rule click here.
ASC Payment Reform
Our societies continue to urge CMS to eliminate the growing disparity in the facility reimbursement rates between hospital outpatient departments (HOPDs) and ASCs. We highlighted that the declining reimbursement for ASCs jeopardizes the ability to perform Medicare cases in this more cost-effective setting. Our societies joined several other stakeholders in urging CMS to set ASC payment at a fixed percentage of the OPPS rate.
Request for Additional GI Services on the ASC List
Our societies recommended that CMS revise the definition of an “ASC covered surgical procedure” to include invasive procedures that do not pose a significant safety risk, would not require an overnight stay when performed in an ASC, and are separately paid under the OPPS. We requested that CMS include the following 16 gastrointestinal codes on the list of ASC codes that are eligible for separate payment.
Additionally, we recommended that CMS revise the definition of an ASC covered surgical procedure to include infusion services.
Modifications to the ASC Quality Reporting (ASQCR) Program
Our societies were pleased that CMS is proposing to delay the mandatory implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS) under the ASCQR Program for CY 2018 data collection. As CMS seeks opportunities to repeal, replace, or otherwise modify burdensome regulations, our societies commented that CMS should finalize its proposal to make OAS CAHPS participation voluntary.
ACG, AGA and ASGE will review the final rules expected to be published in November and will continue to keep you informed about payment changes for CY 2018.