2018 Physician Fee Schedule Final Rule: 5 Things You Should Know

In early November, the Centers for Medicare and Medicaid Services (CMS) posted the Physician Fee Schedule Final Rule for calendar year 2018. The Medicare Physician Fee Schedule (MPFS) rule went into effect on January 1, 2018. The product and regulatory team at Practice Fusion reviewed the 396 page final rule and compiled the most salient takeaways you should be aware of for your practice.

1. CMS finalized several modifications to the rules for accountable care organizations (ACOs) participating in the Medicare Shared Savings Program. The modifications are designed to reduce burden and streamline operations:

   • Revision of the assignment methodology for ACOs to include Federally-Qualified Health Centers (FQHCs) or Rural Health Centers (RHCs) by eliminating the requirement to list each physician working in the program.
   • Reduction of burden for ACOs submitting an initial Shared Savings Program application or the application for use of the skilled nursing facility (SNF) 3-Day Rule Waiver.
   • The addition of three new chronic care management codes (CCM) and four behavioral health integration (BHI) codes to the definition of primary care services used in the ACO assignment methodology.

2. CMS agrees with continued feedback from stakeholders that Evaluation and Management (E/M) guidelines are potentially outdated and need to be revised. CMS will consider the best approaches for such collaboration, and will take the public comments into account as they consider the issues for future rulemaking.

3. Effective January 1, 2018, RHCs and FQHCs will be reimbursed for Chronic Care Management (CCM), general BHI, and psychiatric collaborative care model (CoCM) using two new billing codes created exclusively for RHC and FQHC payment. This payment would be in addition to the payment for an RHC or FQHC visit.

4. The start date for Medicare Appropriate Use Criteria (AUC) is being moved to 2020 to allow practitioners more time to focus on and adjust to the Quality Payment Program.

   • The Medicare AUC program will begin with an educational and operations testing year in 2020 which means physicians would be required to start using AUCs and reporting this information on their claims
   • Clinicians may use a qualified CDS mechanisms to earn credit under the Merit-Based Incentive Payment System (MIPS) as an improvement activity. This improvement activity was included in the 2018 QPP final rule.

5. CMS is changing the policy to separately code and pay for biological biosimilar products under Medicare Part B. Effective January 1, 2018, newly approved biosimilar biological products with a common reference product will no longer be grouped into the same billing code.

A fact sheet on the entire Physician Fee Schedule Final Rule is available on the CMS website.

As a new year is upon us, you can feel confident that Practice Fusion’s team of experts is here to guide you through the ever evolving healthcare landscape. At Practice Fusion, we believe that your practice is our priority.