Last week the Center for Medicare and Medicaid Services finalized more than 2,000 pages of rules for the Medicare program’s operation in 2019. We don’t have to remind you, the doctors on the front lines, that such overregulation is a chief reason American medicine is sick.
However, because you are supporting AAPS and speaking out, there are positive changes included in the final 2019 rules. Here are a few that you helped achieve:
- The proposed lowering of Medicare payments (by flattening E and M payment levels) for complex Medicare patients has been delayed for at least 2 years, and CMS is reducing certain documentation requirements beginning in 2019. For more details see https://www.cms.gov/newsroom/fact-sheets/final-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year
- Unassigned Medicare claims, filed by physicians with non-Par status, will not be subject to MIPS penalties beginning in 2019. Yet another reason to move to non-Par status as a transition step to opting out of Medicare. CMS referred to comments AAPS made in 2017 (which you helped amplify) in its discussion in the rule related to this change. For a short presentation by Dr. Jane Hughes about the benefits of non-Par status for physicians and their patients, see https://youtu.be/hjqqwlLXHy0?t=630. For details about other final changes to MACRA’s MIPS and APMs for 2019, see https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Year-3-Final-Rule-overview-fact-sheet.pdf
- Off-campus hospital-owned clinics will be paid the same fee for evaluation and management visits as are paid when the visit is performed at a non-hospital owned facility. The change will be phased-in over 2 years beginning in 2019. Currently non-hospital clinics, like independent physician offices, are paid 60% less than hospital-owned clinics for these services. CMS is considering additional future changes to further implement payment parity and cited references from AAPS comments regarding other services that are improperly paid at a higher rate. Of course AAPS seeks to end price controls completely, but while they exist, price controls should not be implemented in a manner benefiting large hospitals, at the expense of private practice, while increasing costs for patients. For more details see: https://www.cms.gov/newsroom/press-releases/cms-finalizes-rule-encourages-more-choices-and-lower-costs-seniors
Special MIPS Alert
Now there is the opportunity to take advantage of a regulatory change you helped achieve last year. CMS has made available a form allowing small practices to apply for an exception to the MIPS EHR performance category. If you are subject to MIPS, and in a practice with 15 or fewer “eligible professionals,” please click here for information on this exception.
Clearly there is much more work to be done, but even small victories are essential in the battle to save American medicine. Thank you for standing with AAPS and your colleagues in this crucial fight.