All eyes are on the new physician fee schedule proposed by the Centers for Medicare & Medicaid Services (CMS), which will be finalized this year and go into effect Jan. 1. The ACR is reviewing the proposal and will be providing comments and recommendations to CMS. And many rheumatologists have payment and coding questions: Will fees increase or decrease? Will stiff requirements be attached to specific codes?
Although there are no clear answers, healthcare experts believe physicians may recognize payment reductions for some services and increases for others. Meanwhile, rheumatologists should be focused on developing strategies to improve quality and decrease overall costs, which will be rewarded under the new schedule, according to Lucy Zielinski, vice president at GE Healthcare Camden Group, a national healthcare business advisory and activation firm in Chicago.
The main focus of the 856-page fee schedule document is to improve the value of primary care services and health outcomes. CMS is also proposing an increase in payments for several care management services, such as those rendered to patients with mobility-related disabilities or complex-care management services.
Some of the service and billing requirements for the chronic management code (99490) may also be eased, says Ms. Zielinski. “Before, some of the requirements [for certain codes] were pretty intense and too difficult for physicians to observe. Last year, Medicare anticipated that a higher volume [of codes with strict requirements] would be submitted, but that was not the case. So CMS is now loosening up some of these requirements and expanding CCM [chronic-care management] coding.”
As an example of restrictions being relaxed, she points to electronic sharing of care plan information. Instead of making this information electronically available 24/7 to other practitioners, the proposed rule would require care plans to be made available in a “timely” fashion to other practitioners, remove the requirement to document the provision of the care plan to the beneficiary using EHR technology and no longer requires physicians to obtain written agreement and patient consent.
Good News for Rheumatologists
Ms. Zielinski says the rule proposes that CMS pay for services for patients with chronic conditions who require complex CCM services (99487 and 99489)—good news for rheumatologists who often treat patients with comorbid, complex conditions. The agency is not, however, proposing to change the requirement that CCM services may be billed only by the one provider who assumes the care management role for a particular patient.