Category Archives: Medicare & Reimbursement

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Medicare Physician Fee Schedule Reductions Partially Offset

The final “2023 Omnibus Bill” which is the spending bill passed by Congress and signed by President Biden at the end of 2022, provides partial relief from the scheduled Medicare Physician Fee Schedule Conversion Factor cuts. As previously reported, the changes to the Medicare Physician Schedule Conversion Factor would have reduced physician reimbursement by 4.5%. … Continue Reading

2022 Medicare Rules for Facility-Based Split/Shared Visits

There has been much discussion and controversy over the new CMS position on billing for split/shared services in facility settings. As originally proposed, and starting in January 2022, if the service was shared among providers (such as physicians and physician assistants), the provider who performed the substantive portion of the visit would be the provider … Continue Reading

“Stark” Rules: Navigating Physician Leases and Subleases

Under the Federal Ethics in Patient Referrals Act (more commonly known as “Stark”), if a physician[1] has a financial relationship with an entity, the physician may not refer patients to the entity for medical services payable by Medicare unless the financial relationship complies with the Stark safe harbors.  Thus, entities that lease or sublease space or … Continue Reading

CMS Policy Summary: 2022 Medicare Physician Fee Schedule, Telehealth Originating Site Facility Fee and Services List, and Physician Assistant Billing

In MLN Matters article MM 12159, CMS has published summaries of the following: Updates to payment policies and Medicare payment rates for services provided by physicians and non-physician practitioners (NPP) Updates to Medicare telehealth services and telehealth originating site facility fee payment amounts Billing for a physician assistant (PA) services  … Continue Reading

2021 Medicare Fee Schedule Conversion Factor Reduction Reversed

CY 2021 Physician Fee Schedule Update On December 27, 2020, the Consolidated Appropriations Act modified the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS): Provided a 3.75% increase in MPFS payments for CY 2021 Suspended the 2% payment adjustment (sequestration) through March 31, 2021 Reinstated the 1.0 floor on the work Geographic Practice Cost … Continue Reading

Proposed 2021 Medicare Physician Fee Schedule Changes

Attached is a link to the fact sheet for “proposed policy, payment, and quality provisions changes to Medicare physician fee schedule for calendar year 2021”. Among other things, Centers for Medicare & Medicaid Services (CMS) proposes to: Significantly decrease the Medicare Work Relative Value Unit (WRVU) conversion factor from $36.09 to $32.26 Significantly revise the … Continue Reading

CMS 2021 Fee Schedule Expands ASC Procedures

Centers for Medicare & Medicaid Services (CMS) published the new hospital outpatient and ambulatory surgical center fee schedule for 2021 on August 12, 2020 at this this link:  https://www.federalregister.gov/documents/2020/08/12/2020-17086/medicare-program-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center-payment As part of the proposed revisions, CMS intends to transfer over 1,500 procedures from the “inpatient only” category, including 266 musculo-skeletal procedures as of 2021, the … Continue Reading

CMS Issues Hospital Price Transparency Rules

As part of the 2019 Medicare annual inpatient prospective payment system (PPS) fee schedule update, CMS has added a “rule” requiring hospitals to publish a list of standard charges beginning January 2019. CMS explained this initiative under the “Transparency” and “Request for Information” topics in the following link:  https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2019-medicare-hospital-inpatient-prospective-payment-system-ipps-and-long-term-acute-0 CMS subsequently issued two sets of … Continue Reading

2019 Medicare Physician Fee Schedule Provides Future “Telehealth” or “Communication-Based” Billing Opportunities

The final Medicare 2019 Physician Fee Schedule https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/index.html rule was posted on November 1, 2019, to be effective January 1, 2019.  It includes Section II(D) entitled “Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services”, with several subsections. Brief communication technology-based services (EG Virtual Check-In) (HCPCS Code G2012) Remote evaluation of prerecorded patient information (HCPCS … Continue Reading

2019 Proposed Medicare Fee Schedule

The 2019 proposed Medicare Fee Schedule was published on July 27, 2018 by CMS at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf. Pages 61 through 91 of the Executive Summary are devoted to: Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services.  Click here to read: Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services. This subsection is devoted to explaining both … Continue Reading

Medicare Telehealth Services

Just as a point of providing information, please note that CMS has revised its Medicare Learning Network (MLN) booklet for telehealth services.  The February 2018 edition is included in this link.  https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/TelehealthSrvcsfctsht.pdf The 2019 proposed Medicare Physician Fee Schedule Rule also seeks comments on proposed expansion of telehealth services.  That will be the subject of … Continue Reading

CMS Announces Bundled Payments Care Improvement Model

On January 11, 2018, CMS announced a new voluntary episode payment model (bundled payments for care improvement advanced–BPCI Advanced) that will test a new iteration of bundled payment for the following thirty-two (32) clinical episodes: 29 Inpatient Clinical Episodes Acute myocardial infarction Back & neck except spinal fusion Cardiac arrhythmia Cardiac defibrillator Cardiac valve Cellulitis … Continue Reading
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