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Regulatory Update July 2016 by
Steven Lash
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
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
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)

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Regulatory update july 2016 by steven lash

  • 1. Regulatory Update July 2016 by Steven Lash
  • 2. 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
  • 3. 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
  • 4. 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)