Regulatory update of July 2016 by Mr Steven Lash

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Regulatory Update July 2016 by Steven Lash
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Regulatory Update

• MACRA aka Quality Payment Program (QPP)
• MACRA Rules have been analyzed
• A QPP team has been established to create a
  strategy and business plan including items for
  road map
• Waiting on publication of CPC Healthcare
  Information Technology
• Discussion that QPP will be delayed until July
  2017
• CMS reported that only 275,000 Medicare patients
  were participating in CCM in 2015

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2017 Preliminary Rulemaking for Physician Fee
Schedule (PFS)

• Published July 7, 2017 Final Rules published
  late October/early November
• Proposed conversion factor drops very slightly
  for 2017
• In 2016 it was 35.8043
• It 2017 it will be 35.7751 
• 42 becomes 41.94 PMPM.
•  CMS proposes to add two new CCM codes
• 99487 Complex chronic care management services
• Same criteria as 99490
• 60 minutes of clinical staff time
• RVU reimbursement is 60 higher than 99490
• 99489  Each additional 30 minutes of clinical
  staff time
• In addition to the CPT code for primary procedure
• Slightly less reimbursement than the base code

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2017 Rulemaking- continued

• Waive the face-to-face visit requirement
• Mentioned to CMS in April that it should
  eliminated as this hinders growth
• If physician does enroll patient during a complex
  visit then the physician will receive additional
  reimbursement
• Clarifying and narrowing the 24/7 access standard
  
• eliminated the necessity for this beyond current
  practice
• Clarifying the transitions of care standard
• Loosening the standard so no longer required
  electronically
• Removing the written consent form requirement
• Will make enrolling quicker and easier
• Eliminated the direct supervision requirement for
  Rural Health Centers (RHC) and Federally
  Qualified Health Centers (FQHC)