News and noteworthy information for September 2017:

• ISASS Comments on 2018 Proposed Physician Fee Schedule
• ISASS Comments on Proposed Hospital Outpatient and ASC Rule
• Quality Payment Program – Pick Your Pace – Avoid Losing 4% of your Medicare Reimbursements
• Regulatory Relief Initiatives

ISASS Comments on 2018 Proposed Physician Fee Schedule

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 issue the final 2018 rule by November 1, 2017.

ISASS submitted comments to CMS in support of the RUC-recommended value of the new bone marrow aspiration code for spine surgery (2093X) as well as comments in support of CMS’ proposal to designate CPT code 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. Click here to read ISASS’ comment letter. Click here for a full summary of the proposed rule and here for a comprehensive comparison of RVUs and reimbursements of spine procedures from the 2017 final rule to the 2018 proposed rule.

ISASS Comments on 2018 Proposed Hospital Outpatient and ASC Rule

On July 13, 2017, the Centers for Medicare & Medicaid Services (CMS) released the 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System policy changes, quality provisions, and payment rates proposed rule. CMS will issue the final 2018 rule by November 1, 2017. (Please note that physician payment is made under the Physician Fee Schedule; hospitals are paid for outpatient services under the OPPS and ASCs are paid under the ASC payment system, both detailed in this rulemaking.)

ISASS submitted comments to CMS in support of the addition of CPT codes 22856 (Total disc arthroplasty (artificial disc), anterior approach, including discectomy with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); single interspace, cervical) and 22858 (Total disc arthroplasty (artificial disc), anterior approach, including discectomy with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); second level, cervical (list separately in addition to code for primary procedure) to the list of ASC-covered procedures. ISASS also provided comments on CMS’ proposed new all-cause ASC quality measure, ASC-17, to measure unplanned hospital visits within seven days of an orthopedic procedure performed at an ASC.

Click here to read ISASS’ comment letter. Click here for a full summary of the proposed rule and here for a comprehensive comparison of reimbursements for spine procedures in both the Hospital Outpatient and ASC settings from the 2017 final rule to the 2018 proposed rule.

Quality Payment Program – Pick Your Pace – Avoid Losing 4% of your Medicare Reimbursements

Have you picked your pace for reporting in 2017? The Quality Payment Program (QPP) is the new physician payment system created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and is administered by the Centers for Medicare and Medicaid Services (CMS). Because the QPP is new in 2017, you need to know how to participate in the QPP’s “pick your pace” options for reporting. This is especially important for those who have not participated in past Medicare reporting programs and may be less knowledgeable about the steps to avoid being penalized under the QPP.

The AMA, ISASS and other specialty societies stressed to CMS the importance of establishing a transition period to QPP and, as a result, you only need to report at least one quality measure for one patient during 2017 in order to avoid a payment penalty in 2019 under the Merit-based Incentive Payment System (MIPS).

A short video developed by the AMA, “One patient, one measure, no penalty: How to avoid a Medicare payment penalty with basic reporting,” offers step-by-step instructions on how to report so you can avoid a negative 4-percent payment adjustment in 2019. Also on this website, there are links to CMS’ quality measure tools, an example of what a completed 1500 billing form looks like, a link to the CMS MIPS eligibility tool, and other materials. Additionally, the AMA recently released a new customizable resource, the MIPS Action Plan, to help you think strategically about how to successfully participate in MIPS in 2017.

If you need more information on the QPP and are wondering how to start participating, plan on joining this 1-hour webinar hosted by the AMA that breaks down the complexity of the MIPS track of the QPP into specific actionable steps. Click here to register for the webinar on Wednesday, October 18, 2017 from 1:00PM to 2:00PM ET.

Regulatory Relief Initiatives

Elected officials and policymakers are slowly shifting attention to regulatory relief efforts including ways to decrease regulatory burden on surgeons and other healthcare professionals. Following an announcement of a Medicare Red Tape Relief Project this summer by House Health Subcommittee Chairman Pat Tiberi (R-OH), the Centers for Medicare and Medicaid Services (CMS) asked stakeholders to submit comments 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 as part of the 2018 proposed rulemakings.

The AMA has developed a regulatory relief dashboard to track regulatory “wins” and future deregulation priorities. If you have specific suggestions for ways to decrease regulatory burden on your practice, please email your ideas to ISASS (liz@isass.org) so they can be included in future correspondence to CMS.

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