How the proposed 2019 Medicare Physician Fee Schedule can impact GIs — 12 insights

The American College of Gastroenterology, American Gastroenterological Association and American Society of Gastrointestinal Endoscopy released a joint address on CMS' 2019 Medicare Physician Fee Schedule proposed rule.

The rule has several significant policy and payment changes, as well as multiple proposals for year three of the Quality Payment Program. The three organizations are evaluating the rules and plan to submit comments to CMS around Nov. 2.

Here's what you should know:

Medicare Physician Payment
1. CMS plans to increase the 2019 Proposed Conversion Factor 0.03 percent, from $35.99 to $36.05.

2. CMS proposed a new reimbursement methodology for evaluation and management services. Under the proposals, a new patient level 2-5 and established patient level 2-5 would receive a blended payment.

3. CMS is also changing how physicians document office and outpatient evaluation and management visits. The proposed changes will allow physicians to cite time when selecting visit level and documenting the visit focus their documentation on what has changed or the pertinent items that have not changed and allowing for medical records to be reviewed and verified instead of reentered.

4. CMS is also proposing several new G codes as E/M add-on services. The public said two GI codes were potentially misvalued. 45385 - Colonoscopy with lesion removal and 43239 - EGD biopsy single/multiple were said to have a systematic overvaluation of work RVUs. The societies are working to ensure the GI codes will be properly valued.

5. CMS is also proposing a billing service for when providers check in on patients or address concerns through the telephone or other telecommunication devices. Providers could bill whenever remote evaluation is used to determine whether additional services are needed.

Quality Payment Program
6. CMS made several proposals to the Quality Payment Program for 2019 as well:

Performance threshold would increase from 15 points to 30 points
Quality would decrease from 50 percent to 45 percent
Cost would increase from 10 percent to 15 percent
Merit-based Incentive Payment System would be adjusted from +/- 5 percent to +/- 7 percent
Improvement activities and advancing care/promoting interoperability would stay the same at 15 percent and 25 percent, respectively

7. To avoid a negative payment adjustment, providers must have a MIPS score equal to or greater than the performance score. The payments would be based on 2019 and would apply to payments in 2021.

8. CMS is removing 34 quality measures including: QPP185.

9. CMS wants to add a cost measure category for screening/surveillance colonoscopy to the performance category, starting in 2019.

10. CMS is also changing the Advancing Care Information performance category to "Promoting Interoperability."

11. Additionally, CMS is tailoring some policies to small practices. These practices will be able to use a claims-based measure submission option. However, CMS is eliminating the five-point bonus and potentially applying a three-point bonus in its place.

12. Finally, CMS wants to increase the Advanced APM Certified EHR Technology threshold to require at least 75 percent of eligible clinicians to use CEHRT and participate through advanced APMs and other payer advanced APMs.

For the full breakdown, click here.

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