- CMS is proposing to expand billable telemedicine service, eliminate 34 Merit-based Incentive Payments System measures and reduce the add-on amount for Part B drugs from 6% to 3% in the Medicare Physician Fee Schedule (PFS).
- CMS Administrator Seema Verma told reporters Thursday the proposed rule's changes to the Quality Payment Program would save "approximately 51 hours of clinic time per physician per year" in what she said is "one of the most significant reductions in provider burden ever taken by any administration." CMS, however, is not reducing the MIPS reporting period to 90 consecutive days, as recommended by industry associations.
- The proposal would make other changes to MACRA to allow hospital-employed physicians to use facility-based reporting, give more options for low-volume providers to participate in MIPS and affirm that Medicare Advantage plans will qualify as alternative payment models through a new demonstration program.
The overarching theme in the massive proposed rule is the agency's attempt to reduce the administrative burden for physicians. Also notable are the new billing methods for telemedicine services. One of the biggest roadblocks for growth of virtual care has been a lack of specific billing codes and clear reimbursement models for providers using it.
CMS is proposing new payments for virtual check-ins, prolonged preventive services and the evaluation of patient-submitted images and videos.
Industry groups mostly applauded the telemedicine changes and the efforts to pare down reporting requirements, but also noted that CMS did not accept some changes they have been advocating. The American Hospital Association criticized the agency for continuing what it called "short-sighted policies on the relocation of existing off-campus hospital outpatient departments."
CMS specifically noted in the proposed rule it is not changing payment differentials between services provided at outpatient facilities on and off hospital campuses, saying it believes current rates encourage "fairer competition between hospitals and physician practices by promoting greater payment alignment between outpatient care settings."
AHA, in its statement, disagreed. "These 'site-neutral' policies ignore the need for hospitals to modernize existing facilities so that they can provide the most up-to-date, high-quality services to their patients and communities," AHA said in a statement. "We also continue to urge CMS to improve its payment methodology to better account for the fact that the outpatient payment system includes many more services in its payment rates than the PFS."
The changes to MIPS include removing a number of quality measures that CMS says clinicians believe to be procedurally-based and low-value and streamlining certain E&M coding requirements. "Time spent at the computer documenting and coding for visits is time doctors could be spending with their patients," Verma told reporters.
Despite the reduced reporting requirements, industry associations like Medical Group Management Association were disappointed to see CMS continue its "burdensome 365-day MIPS quality reporting policy" rather than adopt the 90-consecutive-day reporting period recommended earlier this year by groups such as the American Medical Association.
“Reducing the reporting burden would allow more physicians to participate in MIPS and focus the program on rewarding quality care rather than quality reporting," according to the MGMA statement. "Requiring medical groups to submit excessive amounts of data to the government has little impact on the quality of care delivered to Medicare beneficiaries."
The proposed rule could be a boon for telemedicine, especially for use among rural Medicare patients and providers. The agency proposed payment for rural health clinics and Federally Qualified Health Centers for telemedicine and remote evaluation services without an associated billable visit. The rule would expand the list of Part B services that can be delivered via telehealth, including longer visits for patients with complex needs.
Verma emphasized that the rule is designed to augment office visits, not replace them.
CMS is also proposing to require MIPS-eligible clinicians to use 2015 edition certified EHRs starting with the 2019 reporting period.
The agency has previously rewarded use of the more recent editions but backed away from forcing it. MGMA slammed the change. “Today’s rule proposes to require physicians to deploy costly EHR upgrades for 2019 and takes further steps toward implementing burdensome appropriate use criteria," the group wrote. "At first glance, the rule doesn’t meet MGMA’s definition of administrative simplification.”
In line with the Trump administration's efforts to tackle the opioid crisis, CMS is also seeking comment on the creation of a bundled episode of care for substance use disorders as well as regulatory changes and programs that would improve access to care for those Medicare patients.