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7 things to know about the 2019 Physician Fee Schedule Final Rule

The Centers for Medicare and Medicaid Services (CMS) released the 2019 Physician Fee Schedule Final Rule. This regulation includes changes to Medicare reimbursement policies and the Quality Payment Program (QPP) that go into effect beginning in January 1, 2019.

Here is a high-level overview of seven key provisions that physician practice providers should know about:

1. Streamlined evaluation and management (E/M) payment to reduce clinician burden.

CMS finalized changes aimed at reducing administrative burden and improving payment accuracy for E/M visits. Some changes will bring immediate relief beginning on January 1, 2019, while other proposed changes to documentation, coding and payment will not go into effect until 2021.

For example, the final rule allows practitioners to review and verify certain information in a patient's record that is entered by ancillary staff or the patient, rather than re-entering the information themselves. For 2021 and beyond, CMS will consolidate the payment rate for E/M visit levels 2 through 4, while maintaining the payment rate from E/M visit level 5. CMS also finalized the adoption of a new “extended visit” add-on code to account for the additional resources required when practitioners need to spend extended time with the patient.

2. Reimbursement for communication technology-based services.

CMS will pay physicians for their time when they check in with Medicare beneficiaries via telephone or another telecommunications device.  They will also be paid for the time it takes to review a video or image sent by a patient to assess whether a visit is needed, sometimes referred to as “virtual check-in.”

3. Expanded list of Medicare reimbursable telehealth services.

The 2019 Physician Fee Schedule Final rule expands telehealth services in two areas. One expansion is the addition of HCPCS codes G0513 and G0514 (prolonged preventive service(s)) to the list of approved telehealth services. Additionally, CMS is implementing a provision from the SUPPORT Act, the recently-passed law addressing the opioid crisis, to enable patients to access telehealth services from home. Previously, patients suffering from substance use disorder or a co-occurring mental disorder were required to seek treatment at a qualifying treatment center.

4. Merit-based Incentive Payment System (MIPS) eligibility expanded to include non-physician healthcare providers.

CMS is expanding the MIPS program to include a variety of new clinician or ancillary clinician types previously excluded. Physical therapists, occupational therapists, speech language pathologists, audiologists, clinical psychologists, registered dietitians and nutrition professionals are now included in the definition of MIPS eligible clinicians. Non-physician healthcare providers are encouraged to check their participation eligibility at qpp.cms.gov and to begin learning about the performance year 2019 MIPS requirements.

5. Opt-in policy to MIPS for smaller practices. 

CMS also finalized an opt-in policy that allows some clinicians who otherwise were left out due to the low-volume threshold the opportunity to participate in MIPS. Clinicians must exceed at least one (not all) of the low-volume threshold criteria: (1) billing less than, or equal to $90,000 in Part B allowable charges for covered professional service, (2) providing care to less than, or equal to 200 Part B enrolled beneficiaries, or (3) providing less than, or equal to 200 covered professional services under the Physician Fee Schedule.

The ability to opt-in gives the opportunity to earn a positive payback adjustment, without first satisfying the previously needed requirements for participation. More providers will be eligible, creating a greater pool for sharing of data and information that will work to better the healthcare environment.

6. Streamlined MIPS quality measures

For 2019, CMS finalized the addition of eight MIPS quality measures, including four based on patients' reporting of their outcomes, and the removal of 26. This is part of CMS’ larger “Meaningful Measures” effort, through which it is attempting to streamline the documentation and reporting requirements associated with programs such as MIPS.

7. Site-neutral payment policies

Under the final rule, CMS will continue site-neutral payment policies, which means that off-campus facilities built after Nov. 2, 2015, will be paid 40% of the Outpatient Prospective Payment System (OPPS) amount for 2019. CMS also recently released a separate OPPS final rule for 2019, which can be accessed here.

For more information about these provisions and others not mentioned here, visit the CMS 2019 Physician Fee Schedule Final Rule Fact Sheet.

Allscripts will dive into the requirements to assess product development impact and where we see the greatest opportunities for our clients stemming from the rule. Allscripts clients can learn more about regulatory updates in the MACRA Quality Payment Program (QPP) ClientConnect group and on our blog.

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