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Highlights of the CMS Final Rules Issued for Quality & Payment CY 2018

CMS FINAL RULE PFS CY 2018

There were a lot of changes in the final rule published by CMS for the Physician Fee Schedule CY 2018. Some of the more notable changes are listed below for your convenience:

Telehealth Expansion

CMS received many requests to expand telehealth geographically. They again responded with “we have the authority to add to the list of telehealth services based on our annual process, but cannot change the limitations relating to geography, patient setting, or type of furnishing practitioner because these requirements are specified in statute”.

Remote Device Monitoring Unbundled

CMS elected to unbundle CPT Code 99091 for 2018. General requirements are:

  1. Minimum of 30 minutes of physician or QHP time (i.e. not clinical staff)
  2. It will require that an ABN be obtained from the patient and documented in the chart, whether this is written, or verbal, has not yet been determined.
  3. They must have seen the provider for a F2F visit (level 2 or higher) in the last 12 months
  4. It can be billed in the same month as CCM although the time counted for one service cannot be counted for the other
  5. It can be reported once every 30 days maximum

Psych & Cognitive Impairment Code Changes

  • HCPCS G0505 is being replaced by CPT 99483 for CY 2018.
  • HCPCS G0502, G0503, G0504, and G0507 are being replaced by 99492, 99493, 99494, and 99484 respectively for CY2018.

General Care Management Services

CMS is breaking out the coverage of CCM and BHI services for FQHCs and RHCs into a separate new category called “General Care Management”. RHCs are required to submit claims for care management services on an institutional claim form (i.e. CMS 1450 aka UB-04). There will be no geographic adjustments for FQHCs or RHCs on these codes.

2018 Conversion Rate

35.9996

Changes to the 2018 PQRS Payment Adjustment

Satisfactory reporting requirements were reduced from 9 measures to 6 measures.

MSSP/ACOs: Relation to FQHCs & RHCs

To reduce the burden of attribution when FQHCs and RHCs are participating in ACOs, they have removed the attestation for physicians that states their ACO participation. In addition, they have added that all RHC and FQHC claims will be used to establish beneficiary eligibility for assignment/attribution. Eff 1/1/2019.

All FQHCs and RHCs services are going to be considered primary care services eff 1/1/2019 to reduce administrative burden of attribution when participating in ACO models.

CCM codes and BHI codes were added as designated primary care services under MSSPs.

MDPP Changes

Effective date changed to April 1, 2018 to allow time for suppliers to register with the CDC and Medicare as a MDPP supplier.

Virtual Services: “In section III.K.3. of this final rule, we explain that the MDPP expanded model covers in-person MDPP services (other than ad hoc virtual make-up sessions discussed in section III.K.2.c.iv.(3) of this final rule), and thus, explain why we are not currently finalizing any policies related to MDPP services furnished 100 percent virtually and state that we are considering a separate model under CMS’s Innovation Center authority to test and evaluate virtual DPP services.”

CMS FINAL RULE QUALITY PROGRAMS & PAYMENTS CY 2018

Notable changes, per MGMA, the final rule will change MIPS in the following ways:

  • Quadruples the reporting period for the quality component of MIPS from 90 days to one calendar year;
  • Delays the mandate to move to 2015 Edition Certified EHR Technology;
  • Increases the low-volume threshold exclusion to $90,000 in Medicare Part B allowed charges or 200 Medicare Part B patients;
  • Counts the criticized cost component as 10% of the MIPS final score;
  • Provides additional flexibility for small group practices; and

Offers a virtual group option for solo practitioner and small practices to aggregate their data for shared MIPS evaluation

Resources:

  • MGMA.com
  • Federal Register

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