by Mandy Pewitt
Director, Analytics and Information Technology
The CMS 2018 Medicare Physician Fee Schedule Proposed Rule is scheduled to be published this Friday, July 21. CMS will accept comments through September 11, and the final rule will be published during the last week of October. While these changes are still in the proposal stage, our goal is to keep you informed of any impact to your practice. Below is a summary of some of the proposed changes:
2% Increase in Reimbursement for Professional-Only Practices
As of now, the proposed rate changes for radiation oncology professional practices will lead to an overall increase in reimbursement of approximately 2%. This increase is a combination of a slight increase in the conversion factor as well as increases to the work RVUs for several radiation oncology codes. Specifically, reimbursement for the physician clinical treatment planning codes, the weekly management code, the physician component of both the 3D and IMRT physics plans, and the professional work associated with treatment devices, are proposed to increase between 2% and 2.5%.
The overall impact to free-standing centers will be an approximate 1% increase in reimbursement in 2018.
Continued Use of G-Codes in 2018
Radiation treatment delivery will continue to be billed using two different code sets according to location. Hospitals will continue to bill codes 77402, 77407, and 77412 for conventional treatment delivery and codes 77385 and 77386 for IMRT treatment delivery. Free-standing radiation centers and non-excepted hospital off-campus PBDs (hospital owned facilities acquired after November 2015 that are located greater than 250 yards from the main campus) will bill for treatment delivery using the set of G-codes established in 2015.
Proposed Management Code for Superficial Radiation Treatment Planning and Management – GRRR1
In 2015, CMS limited the codes that could be reported with superficial radiation treatment as defined by CPT code 77401. Related services such as the clinical treatment planning code, isodose planning, physics consult, and treatment management were bundled into the delivery code. Any physician work associated with superficial treatment was accounted for only in the evaluation and management services. CMS is now proposing a new code, GRRR1, which would account for all physician services associated with superficial radiation treatment. This code will have an approximate reimbursement of $485.
Review of Evaluation and Management Guidelines
CMS is seeking comments from stakeholders, regarding a review of Evaluation and Management Guidelines. The current guidelines date back to 1995 and 1997. The proposed multi-year review would seek to reduce the clinical burden and establish meaningful updated guidelines for correct documentation.
Reduction to the Value Modifier Downward Payment Adjustments to be Applied to 2018 Payments
Many of our clients reported PQRS data over the past several years, and, thus avoided the penalties associated with the PQRS and Value Modifier programs. The previous downward adjustment for failure to participate in the Value Modifier program for 2016 was a (-2%) payment adjustment to be applied in 2018 for groups of 9 or fewer physicians. CMS has proposed reducing this previously finalized adjustment from a (-2%) adjustment to a (-1%) adjustment in 2018. The Value Modifier program ended in 2017 when CMS transitioned to the new MIPS program which will be applied to 2017 dates of service and 2019 payments.
For more information on the proposed rules, refer to the CMS Proposed Rules Fact Sheet. If you have additional questions or would like your practice to benefit from RBS's MIPPS Implementation Program, please contact us to schedule an on-site engagement. We'd be happy to help!