The physician fee schedule for 2017 proposed by the Centers for Medicare & Medicaid Services has raised a red flag for the American College of Surgeons (ACS).
A proposal related to data collection on the transition of all 10- and 90- day global codes to 0-day codes in the proposed physician fee schedule 2017 is the area of greatest concern to the ACS. The provision would require all surgeons and other physicians who receive payment from these codes to devote many hours to collecting and reporting these data.
Two years ago, the CMS had pushed this exact transition through in regulation. However, Congress halted that transition in the Medicare Access and CHIP Reauthorization Act (MACRA), instead directing the CMS to study the effects of the transition by collecting data from a “representative sample” of physicians who receive payment from these codes.
For most surgical procedures, Medicare pays surgeons for either 10 or 90 days of care that include the procedure itself and postoperative care. Most global codes are 90-day codes. The CMS would have debundled the global payments 2 years ago had Congress not intervened.
However, in the proposed physician fee schedule update for 2017, the CMS would require all physicians to report data on these codes, something the ACS believes is overly burdensome.
“ACS believes that this proposal does not align with the MACRA requirement that CMS only collect data from a representative sample of physicians performing 10- or 90-day global codes,” ACS Regulatory Affairs Manager Vinita Ollapally told ACS Surgery News. “ACS is currently pursuing a legislative strategy that urges CMS to not finalize the proposal to collect data from all practitioners who perform 10- and 90-day global services, and instead revise the policy to collect data on 10- and 90-day global services from a ‘representative sample’ of practitioners.”
The college is developing a definition for what it believes that representative sample should include and expects to have that ready when the ACS files its comments on the physician fee schedule update proposal. Comments on the proposal are due Sept. 6.
The proposed update, published July 15 in the Federal Register, brings in several new policies aimed at improving physician payment for caring for patients with multiple chronic conditions; mental and behavioral health issues; and cognitive impairment or mobility-related issues.
Among the provisions in the 800+ page proposal are revised billing codes that would more accurately recognize the work of primary care and other cognitive specialties. The changes, according to the CMS, will help “better identify and value primary care, care management, and cognitive services.”
The agency is proposing several coding changes that “could improve health care delivery for all types of services holding the most promise for healthier people and smarter spending, and advance our health equity goals,” according to a CMS fact sheet.
The proposed fee schedule also would update how quality is measured and reported by accountable care organizations in the Medicare Shared Savings Program, align Accountable Care Organization reporting with the Physician Quality Reporting System, and change how beneficiaries are assigned to an ACO. Potentially misvalued services also would continue to be reviewed under the proposal.
The agency is also proposing a code to allow for the payment of advanced care planning services furnished via telehealth.