CY 2016 Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Medicare Part B (CMS-1631-P) Summary of Identified Key Provisions in the Proposed Rule Deadline for Comment Submission: September 8, 2015 at 5pm (Section references refer to the preamble of the proposed rule.) Section II. Provisions of the Proposed Rule for PFS SUBSECTION E. IMPROVING PAYMENT ACCURACY FOR PRIMARY CARE AND CARE MANAGEMENT SERVICES Seeking comments on ways to recognize the different resources involved in delivering broad-based ongoing treatment, beyond evaluation and management services Seeking comments on establishing a separate payment for collaborative care, specifically on the parameters and resources involved in collaboration between specialist and primary care practitioner o Includes looking at technology supports for collaborative care o Includes consideration of a potential CMMI model with a waiver of beneficiary financial liability for interprofessional consultation as part of collaborative care SUBSECTION I. VALUATION OF SPECIFIC CODES 6. C. Advance Care Planning Proposing to assign the status of “A” (Active code), to two advance planning codes. (“A” (active code) means these codes are separately payable under the PFS. There will be RVUs for codes with this status.” The presence of an “A” indicator does not mean that Medicare has made a national coverage determination regarding the service. Contractors remain responsible for local coverage decisions in the absence of a national Medicare policy.): o CPT code 99497: Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), by the physician or other qualified health professional; first 30 minutes, face-to-face with the patient, family member(s) and/or surrogate; o CPT code 99498 (add-on code): Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), by the physician or other qualified health professional; each additional 30 minutes (List separately in addition to code for primary procedure). o Seeking comment on the proposal, including whether payment is needed and what type of incentives this proposal creates. And, whether payment for advance care planning is appropriate in other circumstances such as an optional element, at the beneficiary's discretion, of the annual wellness visit. **CMS administrators have stressed they welcomed recommendations for implementation of payment for advanced care planning** Section III. Other Provisions of the Proposed Regulations SUBSECTION C. CHRONIC CARE MANAGEMENT SERVICES FOR RURAL HEALTH CLINICS AND FEDERALLY QUALIFIED HEALTH CENTERS (§ 405.2462 PAYMENT FOR RHC AND FQHC SERVICES AND § 405.2464 PAYMENT RATE.) New proposals on payment, beneficiary eligibility, and scope of services included in chronic care management SUBSECTION H. PHYSICIAN COMPARE WEBSITE Includes plans to consult and test language with consumers to ensure that Physician Compare is as consumer friendly and consumer focused as possible Seeking comment on potential measures that would benefit from future public reporting on physician compare Seeking comment on adding Medicare Advantage physicians to the website Seeking comment on proposed new benchmark for quality measures. CMS wants the proposed benchmark to allow consumers to more easily evaluate the information published by providing a point of comparison between groups and between individuals. Seeking comment on measure stratification by race and ethnicity and gender, as well as the inclusion of other measures of health equity SUBSECTION I. PHYSICIAN PAYMENT, EFFICIENCY, AND QUALITY IMPROVEMENTS— PHYSICIAN QUALITY REPORTING SYSTEM (§ 414.90 PHYSICIAN QUALITY REPORTING SYSTEM (PQRS).) 7. Request for Input on the Provisions Included in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) MIPS: seeking comment on what activities could be classified as clinical practice improvement activities according to the current definition. The current definition of clinical practice improvement must include the following sub-categories: 2 o Expanded practice access o Population management o Care coordination o Beneficiary engagement o Patient safety and practice assessment o Participation in alternative payment model Planning to issue a forthcoming RFI on alternative payment models. In advance of the RFI, CMS is seeking comment on approaches to implementing any of the APM topics listed below, including in provisions not enumerated above, and any other related concerns. o The criteria for assessing physician-focused payment models; o the criteria and process for the submission of physician-focused payment models eligible APMS, o qualifying APM participants; o the Medicare payment threshold option and the combination all-payer and Medicare payment threshold option for qualifying and partial-qualifying APM participants; o the time period to use to calculate eligibility for qualifying and partial-qualifying APM participants, eligible APM entities, quality measures and EHR use requirements; and o the definition of nominal financial risk for eligible APM entities. SUBSECTION K. POTENTIAL EXPANSION OF THE COMPREHENSIVE PRIMARY CARE INITIATIVE Seeking comment on the potential expansion of the program and the following elements: o Practice readiness: practices currently are asked to reorganize their work flows to accomplish the five comprehensive primary care functions. CMS is interested in understanding the proportion of primary care practices ready for these transformation expectations and whether readiness varies systematically for differently structured practices (for example, small primary care practices, multispecialty practices, and employed primary care practices within integrated health systems). o Practice standards and reporting o Practice grouping o Interaction with state primary care transformation initiatives: Various states are leading their own efforts to transform primary care practices. Although these efforts may have processes and goals that are similar to those in the CPC initiative, requirements and outcomes can differ in important ways. CMS is interested in whether a potential expansion of the CPC initiative could and 3 should exist in parallel in a state with a separate state-led primary care transformation effort, especially if Medicare is participating in that effort. o Learning activities: CMS is interested in what support practices would require to provide the five comprehensive primary care CPC functions in a potential expansion of the CPC initiative, and the readiness of the private sector to respond to the need for this support. Also interested in the willingness and ability of existing state and regional primary care or patient centered medical home learning collaboratives to support practices in an a potential expansion of the CPC initiative. o Payer and self-insured employer readiness o Medicaid: CMS is interested in whether state Medicaid agencies would be willing to participate in a potential expanded CPC initiative for their fee-for-service enrollees. Also interested in whether Medicaid managed care plans would be willing to participate in a potential expanded CPC initiative. o Quality reporting: CMS is interested in comment on practice readiness to report eCQMs, and payer interest in using practice site level data rather than their own enrollees' information for performance based payments, including shared savings, in a potential expansion of the CPC initiative. o Interaction with CCM fee o Provision of data feedback to practices SUBSECTION L. MEDICARE SHARED SAVINGS PROGRAM (§ 425.20 TO § 425.504) Proposing to add a new quality measure to be reported to CMS – the measure is specific to cardiovascular disease and CMS seeks comment on implementation of the measure Seeking comment on how the HIT measure might evolve in the future to ensure we are incentivizing and rewarding providers for continuing to adopt and use more advanced health IT functionality. Seeking comment on the proposal to exclude services furnished in SNFs from the definition of primary care services will complement our goal to assign beneficiaries (§ 425.20 Definitions.) 4
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