A look inside CMS Physician Fee Schedule final rule

The Centers for Medicare and Medicaid Services late Friday afternoon dropped the final Physician Fee Schedule rule for 2015 and it brings a number of changes that doctors and practice managers need to understand about chronic care, telehealth and meaningful use.

The final rule establishes among its major provisions a chronic care management (CCM) payment rate of $40.39 that can be billed up to once per month per qualified patient. CCM services include development and revision of care plans for patients, communication with other treating health professionals and medication management.

CMS also stipulated that certain services can be furnished to Medicare beneficiaries via telehealth: annual wellness visits (HCPCS codes G0438 and G0439), psychotherapy services (CPT codes 90845, 90846 and 90847), and prolonged evaluation and management services (CPT codes 99354 and 99355).

In addition, the 1,185-page rule includes new details on electronic reporting of Clinical Quality Measures under the EHR Incentive program. The CY2014 PFS final rule required eligible professionals to report CQMs using the most recent version of the electronic specifications and to have EHR technology that is tested and certified to handle those specifications. In CY 2015, EPs will not be required to ensure that their EHR technology is recertified to the most recent version of the electronic CQM specs.

CMS “received feedback from stakeholders regarding the difficulty and expense of having to test and recertify CEHRT products to the most recent version of the electronic specifications for the CQMs. Although we still believe EPs should test and certify their products to the most recent version when feasible, we understand the burdens associated with this requirement."

CMS added this caveat, however: Although the agency is not requiring recertification, EPs must still report using the most recent version of the electronic CQM specs.

And then there’s the status quo. Physician pay under Medicare will drop by 21 percent after April 1, 2015, unless Congress comes up with a fix to the Sustainable Growth Rate formula — or abolishes it altogether.

The Protecting Access to Medicare Act of 2014 provides a 0 percent update for services provided between January 1 and March 31 of 2015. Without any legislative correction, the Medicare conversion factor under the Physician Fee Schedule would drop from $35.80 for the first quarter of 2015 to $28.22 for the remainder of the calendar year.

"By law, we are required to make these reductions in accordance with [sections of PAMA], and these reductions can only be averted by an Act of Congress. While Congress has provided temporary relief from these reductions every year since 2003, a long-term solution is critical,” the rule states. “We will continue to work with Congress to fix this untenable situation so doctors and beneficiaries no longer have to worry about the stability and adequacy of payments from Medicare under the PFS."