AADA on the pulse: CMS proposed Medicare physician fee schedule offers mixed bag for dermatology
The American Academy of Dermatology Association (AADA) has conducted an initial review of the recently released 2015 CMS proposed Medicare Physician Fee Schedule and has determined that — pending possible additional changes with the final rule — dermatology as a specialty is slated for a 0 percent change in payments in 2015 (results for individual dermatologists will vary depending on the mix of services). Overall, the 2015 proposed Medicare Physician Fee Schedule offers a mixed bag of policies and changes for dermatology:
Elimination of global periods
CMS raised serious concerns about the accuracy of the valuation and coding of global payments which currently include payment for follow-up visits that typically occur during the global period. Based on its determination that follow-up visits often do not occur, CMS is proposing to eliminate global periods, and value all surgical codes based only on the surgical day of service, and then pay separately for follow-up services. These 10-day global periods would phase out in 2017, and 90-day global periods would phase out in 2018. CMS is seeking input on how a phase-out of global periods might be instituted and the potential impact. The AADA is currently developing a strategy for addressing this significant concern and will continue to provide more in-depth coverage about both the proposal and its effect on dermatology in Member to Member, Dermatology World, Dermatology Advocate and the AAD website.
Six dermatology codes identified as potentially misvalued
CMS identified six dermatology-specific codes as potentially misvalued based on a screen of “high expenditure codes.” The codes include two skin biopsy codes, two nail codes, an adjacent tissue transfer code and a destruction of benign lesion codes (CPT 11100, 11101, 11730, 11750, 14060 and 17110). As a result, the American Medical Association’s Relative Value Scale Update Committee (AMA RUC) will review these codes to determine whether or not the codes require a physician survey to determine if the code values need refinement in the future.
Physician Quality Reporting System (PQRS) cross-cutting measures
In 2015, CMS is proposing a new requirement that at least two of the nine required reported measures must be from a set of cross-cutting measures. The AAD Quality Reporting System (QRS) supports five dermatology-specific measures and eight dermatology-applicable measures to help dermatologists meet these reporting requirements. All five of the current dermatology-specific measures are likely to remain applicable in 2015, and three of the eight dermatology-applicable QRS measures are included in this proposed cross-cutting measure set. Read more about PQRS.
Changes to Sunshine Act
CMS is proposing to reverse the exemption of payments made to speakers for Continuing Medical Education (CME) services within the reporting requirements of the Sunshine Act (Open Payments). Currently, accredited or certified continuing education payments to speakers are not required to be reported through the Sunshine Act.
Academy action on site-neutral payment policy pays off
In addition to the release of the proposed Fee Schedule, CMS also decided to shelve a troublesome site-neutral payment policy that would have used Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS/ASC) fees to value physician services and reduce payments. This would have affected services for which the total payment, when furnished in an office or other non-facility setting, exceeds the total Medicare payment when the service is furnished in a facility — either a hospital outpatient department or an ASC. The AADA strongly advocated against this policy, arguing that the policy does not take into consideration physician practice expenses. Read the AADA’s comment letter on the OPPS/ASC proposed rule.
CMS seeks to develop valuation model for work RVUs outside of the RUC process
Although not included in the proposed 2015 Medicare Physician Fee Schedule, CMS has issued a status report from a project conducted by the Urban Institute, Social & Scientific Systems, Inc., and RTI International that seeks to develop a model for the valuation of work relative value units (RVUs). This project is part of CMS’s efforts to address potentially misvalued services in the Medicare Physician Fee Schedule by developing a process to validate work RVUs outside of the RUC process. The contractors plan to collect information to validate work RVUs in two ways: by observing physician treatment of patients and by studying electronic health records and other forms of data. The contractors will study about 100 physician services – including a number of dermatologic procedures. Read more AADA analysis from the Report’s status update here. The AADA has been closely monitoring the developments of this project, and will continue to review the status update and report its findings as more information becomes available.
AADA advocacy: Next steps
The AADA will continue to analyze the proposed rule for its impact on dermatology and will submit its comments to CMS prior to the Sept. 2 deadline. The AADA will provide additional updates to members in the Dermatology Advocate e-newsletter and on the AAD website. For more information on PQRS, contact Sandy Robinson at firstname.lastname@example.org. For more information on the proposed Medicare Physician Fee Schedule, contact Richard Martin at email@example.com, or James Scroggs at firstname.lastname@example.org.