On July 13, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that updates payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2018. The PFS pays for services furnished by physicians and other practitioners in all sites of service. These services include but are not limited to visits, surgical procedures, diagnostic tests, therapy services, and specified preventive services. CMS will accept comments on the proposed rule until September 11, 2017, and will issue the final rule by November 1, 2017.
As part of the proposed rule, CMS issues proposed values for new codes and codes deemed misvalued. Please see the spine code spreadsheet for a comprehensive comparison of RVUs and reimbursements of spine procedures from the 2017 final rule to the 2018 proposed rule. CMS addresses the following issues relevant to spine in the proposed rule:
- CMS is proposing the RUC-recommended value for a new Category I add-on code (2093X) to report bone marrow aspiration for spine surgery;
- CMS is designating CPT 27279 (Arthrodesis, sacroiliac joint, percutaneous or minimally invasive (indirect visualization), with image guidance, includes obtaining bone graft when performed, and placement of transfixing device) as potentially misvalued. This is a positive step as ISASS has repeatedly communicated with CMS about the value of this code and has shared data with the agency that supports a higher work RVU;
- CMS is proposing to further delay the implementation of Appropriate Use Criteria for Advanced Diagnostic Imaging Services to January 1, 2019;
- CMS is proposing five new modifiers to report patient relationship categories required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA);
- CMS is calling for a multi-year effort to revise the Evaluation and Management Guidelines to accompany a desire to reduce administrative burden to physicians;
- CMS is updating PQRS, EHR Meaningful Use and the Value-Based Modifier to more closely align with the new physician reporting program, MIPS; and
- CMS is requesting public comment on ideas for regulatory, subregulatory, policy, practice and procedural changes to improve the health care system by reducing unnecessary burdens for clinicians, other providers, patients and their families.
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