The 2013 Medicare Physician Fee Schedule was posted by CMS today.
27% SGR Reduction
The most significant issue, of course, will be the proposed 27% Medicare physician fee schedule reduction which will be statutorily imposed because of the sustainable growth rate formula. I am sure everybody is familiar with the annual debacle over the last decade arising from the statutorily imposed physician fee decreases, which have always been postponed by congress and the President. By putting off a permanent fix to this issue, our government leaders simply postpone and exacerbate the problem, because the deduction becomes larger every year. The only possible permanent fix is the elimination of SGR, but the issue is not the inevitable elimination of SGR, but determining a replacement. Given the economic situation, one would expect any permanent replacement to result in some decrease in Medicare spending and therefore some decrease in the physician fee schedule.
Multiple Procedure Payment Reduction (MPPR)
CMS is always looking for opportunities to reduce the reimbursement for multiple procedures that are performed at the same time on the basis that certain relative value unit payments are redundant, leading to overpayment for multiple procedures. In the latest round of reduction, the technical component of certain cardiovascular and ophthalmology diagnostic procedures will be grouped into the MPPR and a new category of MPPR will be included. The new category will be multiple procedures performed by different providers of the same group. Apparently CMS believes that some providers are attempting to skirt the MPPR reductions by having the multiple procedures reported by different providers.
Additional Telehealth Procedures
CMS will add alcohol and drug abuse counseling and certain preventive procedures to the Telehealth package of approved services.
Chronic Pain Management by CRNA
CMS plans to set a Medicare standard for services that can be furnished and billed by CRNAs. The standard would be consistent with existing policy that recognizing state scope of practice laws regarding services that can be furnished and billed by other non-physician providers, a category which includes CRNAs. CMS proposes to allow CRNAs to bill Medicare for, “medical and surgical services that are related to anesthesia and that a CRNA is legally authorized to perform by the state in which the services are furnished.” The proposed language would effectively allow qualified CRNAs to bill Medicare for chronic pain management services in states where it is permitted. See pages 227 through 234.
Face to Fact DME Encounters
CMS will implement a provision that was passed in the Affordable Care Act (ACA), which requires a face to face encounter to justify payment for certain durable medical equipment (DME) items. The ordering physician must document and communicate to the DME supplier that the physician or a physician assistant, nurse practitioner, or clinical nurse specialist has had a face to face encounter with the beneficiary on one of the following dates:
· The date of the order;
· In the 90 days prior to the date of the order; or
· In the 30 days after the order.
The face to face encounter must support the medical necessity of each item of covered DME, and face to face encounters may be performed via Telehealth, provided the Telehealth services meet the Medicare requirements. See pages 249 through 276.