Physicians are praising a new proposal by the Centers for Medicare & Medicaid Services to pay for end-of-life counseling as part of a sweeping draft of updates to its 2016 physician payment schedule.
The proposed fee schedule – the first since repeal of the Sustainable Growth Rate (SGR) formula and enactment of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) – includes modifications to reimbursement policies, changes to misvalued codes, and updates to quality performance metrics for physicians who participate in the Physician Quality Reporting System (PQRS).
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As part of the proposal, released on July 8, two new advance care planning codes would be created to pay physicians for time discussing patient options for advance directives. The first code would cover an initial 30 minutes of the doctors’ time, and the second would cover additional 30-minute blocks as necessary.
Dr. Andrew W. Gurman, president-elect of the American Medical Association, said the proposed rule affirms the need to support conversations between doctors and patients about end-of-life wishes before critical medical events occur. The AMA Current Procedural Terminology (CPT) Editorial Panel and the AMA Relative Value Update Committee (RUC) created the new CPT codes and recommended the associated payments for calendar year 2015.
“This is a patient-centered policy intended to support a careful planning process that is assisted by a physician or other qualified health care professional,” Dr. Gurman said in a statement. “This issue has been mischaracterized in the past and it is time to facilitate patient choices about advance care planning decisions.”
The American College of Physicians (ACP) applauded inclusion of the advance care planning codes, calling it an important step to improve care for Medicare patients with serious illnesses.
“The nation’s physicians believe that conversations among physicians, patients, and loved ones is the standard of care,” ACP President Dr. Wayne J. Riley said in a statement. “The College is pleased that CMS has recognized what the medical community is doing to address the needs and requests made by patients and their loved ones.”
CMS’ proposal also includes updates to the PQRS, the federal program that provides incentive payments to eligible professionals and group practices that report data on quality measures for covered services and/or participate in a qualified clinical data registry (QCDR). The proposal would establish criteria for satisfactory reporting similar to that of previous years, including the general reporting of nine measures covering three National Quality Strategy domains.
Eligible professionals and practices who do not report on PQRS standards in 2016 will see their 2018 Medicare pay cut by 2%. The proposed fee schedule also would eliminate measures that are topped out, duplicative, or are being replaced with more robust measures. If the proposal is finalized, 300 total measures in the PQRS program are slated for 2016.
The proposed fee schedule also would modify the the Medicare Shared Savings Program (MSSP) by:
• Allowing participants to add or delete a measure if it no longer aligns with updated clinical practice or causes patient harm.
• Clarifying how PQRS-eligible professionals participating within an ACO can meet PQRS requirements when their ACO satisfactorily reports quality measures.
• Amending the definition of primary care services to include claims submitted by certain teaching hospitals and excluding those submitted by skilled nursing facilities.
The proposed fee schedule also addresses telemedicine services. CMS says it will pay for telemedicine if the treatment is on the list of approved Medicare telehealth services, and if:
• the service is furnished via an interactive telecommunications system.
• The service is furnished by a physician or authorized practitioner.
• The service is furnished to an eligible telehealth patient.
• The patient receiving the service must be located in a telehealth originating site.
If these conditions are met, Medicare will pay a facility fee to the originating site and make separates payment to the distant site health provider furnishing the service.
CMS is also proposing payment changes for certain specialty services based on codes determined to be misvalued. Specifically, physicians who practice radiation therapy, radiation oncology, and gastroenterology would experience significant decreases to payments for services that they frequently furnish as a result of widespread revisions to the Relative Value Unit (RVU) structure used to establish such codes. Other specialties, such as pathology, would experience significant increases to payments for similar reasons, CMS states. The modifications are a result of an initiative to review misvalued codes and establish new and revised codes.
Meanwhile, CMS is seeking feedback on several components of MACRA, including the definition of clinical practice improvement activities and input on how to define a physician-focused payment model. The agency is also asking for feedback on whether to expand the Comprehensive Primary Care Initiative, a 4-year multipayer pilot that aims to strengthen primary care by offering population-based care management fees and shared savings opportunities to participating health providers.