Proposed Changes to the Medicare Physician Fee Schedule for 2015

By Nancy Clark, CPC, CPB, CPMA, CPC-I

Earlier this month, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that would update payment policies and rates for services furnished under the Medicare Physician Fee Schedule (MPFS) in calendar year 2015.  Significant proposed changes include additional payments for chronic disease management, greater transparency in setting fee schedule amounts and a major revision to the global periods of procedures.

Currently, Medicare pays physicians for chronic care management services as part of a face-to-face visit.  In 2013, Current Procedural Terminology (CPT) codes were introduced for the complex chronic care coordination of services.  These codes include services provided outside of a face-to-face visit for managing two or more chronic conditions. Medicare will continue to emphasize primary care management by beginning to make separate payment for non-face-to-face chronic care management services for beneficiaries under certain conditions.   Chronic care management services include regular development and revision of a plan of care, communication with other treating health professionals, and medication management.

For 2015, CMS is proposing a new process for establishing MPFS payment rates that will be more transparent and allow for greater public input prior to payment rates being selected. Under the new process, payment changes will go through a notice and comment period before being adopted.  These changes will begin for the establishment of the 2016 MPFS.

Recent amendments to the Affordable Care Act have directed CMS to identify potentially “misvalued codes.”  These codes have been identified by reviewing high-expenditure services by specialty that have not recently been reviewed.  Additional measures include a public nomination process through which misvalued codes could be identified by external parties.  Approximately eighty codes will be added to this year’s list.

Directly relating to this initiative, CMS is proposing to transform all 10- and 90-day global codes to 0-day global codes beginning in 2017.  The Office of Inspector General has identified many surgical procedures that include payment for more visits in the global period than are being furnished.  In order to address potential misvaluation of services, it is proposed that visits prior and subsequent to a surgical procedure be billed separately, not inclusive to the surgery.  This initiative could have a profound effect on Medicare reimbursement and billing procedures for surgeons and their staff.

The complete rule can be found here.