The Endocrine Society recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the 2013 Medicare Physician Fee Schedule proposed rule. CMS recommends changes to physician payment policies for the upcoming year and sets the rates at which endocrinologists will be reimbursed for services provided to Medicare beneficiaries. The comment letter, which can be downloaded at www. endo-society.org/advocacy/legislative/letters/, focuses on several areas of particular importance to endocrinologists. Here we present an overview of the Society’s comments on CMS’ recommendations for the 2013 Medicare physician fee schedule.
CMS recommends the inclusion of 264 individual quality measures and 26 measure groups in the 2013 Physician Quality Reporting System (PQRS), a reporting program that uses incentive payments and payment adjustments to encourage health care professionals to use quality measures to report information to the agency. CMS also proposes to align PQRS electronic health record-based reporting measures with those under the Electronic Health Records (EHR) incentive program, another initiative aimed at increasing adoption of health information technology. The Society supports efforts to align these quality reporting programs to reduce the administrative burden that physicians and staff face in reporting quality measures to multiple programs. The Society also supports new individual osteoporosis measures that endocrinologists can use to meet the PQRS requirements and recommends using these as an osteoporosis measures group to encourage post-fracture care coordination.
Value-based Payment Modifier
CMS also provides details on the implementation of a value-based payment modifier (VBM), a payment policy included in the Affordable Care Act to reward physicians who improve quality and reduce costs and to penalize those who do not. To be applied to group practices of 25 or more, the first VBM payments would be made in 2015 and would be based on quality and cost measures reported in 2013. To avoid a penalty in 2015, groups would need to successfully participate in a PQRS group reporting option in 2013. Groups that do not participate in PQRS in 2013 would receive a 1 percent payment reduction in 2015. Groups that successfully meet the PQRS requirements could opt out of the VBM and receive neither a positive nor a negative payment adjustment in 2015 or could choose to have the value-based payment modifier applied and potentially receive a payment increase.
The Society opposes basing the initial VBM on 2013 measures, recommending a delay until 2014 to allow physicians to become better educated about the VBM. This delay would also provide CMS with additional time to work out a number of details that remain unclear.
CMS proposes to include a new group practice reporting option under the e-prescribing quality improvement program that would apply to practices with 2 to 24 eligible professionals. To meet the e-prescribing criteria, practices would need to report 225 electronic prescriptions to qualify for a 0.5 percent incentive payment and to avoid a 1.5 percent penalty on Medicare Part B claims. The Society believes that reporting 225 electronic prescriptions is too burdensome and recommends a tiered approach that would reduce the threshold for smaller practices and make it easier for providers to meet the program requirements.
CMS also proposes to add two new hardship exemptions for the e-prescribing program that would allow eligible professionals or group practices who demonstrate an intent to participate in the EHR quality improvement program, or who successfully do so, to avoid the 1.5 percent e-prescribing penalty in 2013. The Society appreciates CMS’ willingness to include additional hardship exemptions that will allow providers to avoid the 2013 e-prescribing penalty, but believes that a reasonable amount of time to report these exemptions is necessary. In the comment letter, the Society requests that CMS provide at least 90 days for eligible professionals to report a new hardship exemption after the physician fee schedule has been finalized.
Transitional Care Management
CMS proposes to cover transitional care management services for the coordination of a patient’s care in the 30 days following a discharge from a hospital or nursing facility. The Society supports payment for transitional care management services and other non–face-to-face care coordination services, and encourages CMS to evaluate additional opportunities to compensate physicians for the time they spend providing these necessary services.
CMS is expected to finalize the 2013 Medicare physician fee schedule in early November. An overview of the final rule will be detailed in a future edition of Endocrine Insider.