CMS Issues Proposed Rule Changes to the Medicare Physician Fee Schedule for 2016
July 17, 2015
By the EMP Quality Department.
On July 8, 2015, The Centers for Medicare and Medicaid Services (CMS) released a proposed rule changing payment policies, rates, and quality provisions for the Medicare Physician Fee Schedule (PFS). This rule proposes changes to several quality reporting initiatives, including the Physician Quality Reporting System (PQRS), the Value-Based Modifier, and the Electronic Health Record (EHR) Incentive Program. It also will make changes to the Physician Compare website on Medicare.gov.
CMS intends to continue to implement PQRS by proposing requirements for the 2018 PQRS payment adjustment consistent with the 2017 PQRS payment adjustment. CMS proposes to establish the same criteria for satisfactory reporting that was established for the 2017 PQRS payment adjustment, which is generally to require the reporting of nine measures covering three National Quality Strategy domains. If an individual EP or group practice does not satisfactorily report on PQRS quality measures or satisfactorily participate in a QCDR, a 2% negative payment adjustment would apply in 2018.
CMS will be proposing changes to the PQRS measure set to eliminate duplicate measures and to add measures where gaps exists. There will be 300 PQRS measures in the set for 2016 if all measures are finalized. There will also be a reporting option that will allow group practices to report quality measures data using a QCDR.
According to CMS, the 2018 PQRS payment adjustment will be the last adjustment issued under the PQRS. Following 2018, adjustments for quality reporting will be made under the Merit-Based Incentive Program (MIPs).
As part of the 2016 PFS proposed rule, CMS will continue its phased approach to public reporting on Physician Compare. In addition to making all individual and group-level PQRS data publicly available, CMS proposes the following new policies:
- Including an indicator on profile pages for those who satisfactorily report the new PQRS Cardiovascular Prevention measures group
- Make individual-level and group-level QCDR measures publicly available
- Reporting on Value Modifier tiers for cost and quality and indicate if the individual EP or group practice was eligible to but did not report quality measures to CMS
- Publicly report utilization data for individual EPs.
Value-Based Payment Modifier
The Value-Based Payment Modifier (VBM) provides for differential payments under the PFS to groups and other EPs based on the quality and cost of care that they furnish to enrolled beneficiaries in the traditional Medicare Fee-for-Service program. The VBM program is set to expire in 2018 when the Merit-Based Incentive Program takes effect. The proposed changes intend to help with the transition from the VBM to MIPs.
The proposed changes to the 2018 VBM include:
- To use the CY 2016 as the performance period for the CY 2018 VBM
- To continue to apply the VBM in 2018 based on participation in the PQRS by groups and solo practitioners.
- To continue to set the maximum upward adjustment at +4.0 times an adjustment factor for groups with ten or more EPs, +2.0 times an adjustment factor for groups with between two to nine EPs and physician solo practitioners; and, +2.0 times an adjustment factor for groups and solo practitioners that consist only of nonphysician EPs
- To set the amount of payment at risk under the CY 2018 VM to -4.0 percent for groups with ten or more EPs, -2.0 percent for groups with between two to nine EPs and physician solo practitioners, and -2.0 percent for groups and solo practitioners that consist only of nonphysician EPs who are PAs, NPs, CNSs, and CRNAs.
For a complete overview of all of the proposed changes for 2018, visit: http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-07-08.html
CMS is accepting public comments on the CY 2016 PFS proposed rule until September 8, 2015. The proposed rule will be published in the Federal Register on July 15, 2015 here: https://www.federalregister.gov/public-inspection.
CMS will issue the final rule by November 1, 2015.