On July 13, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that includes proposals to update payment rates and policies, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) for calendar year (CY) 2018.

Conversion Factor and Overall Payment Update

CMS proposes the conversion factor for CY 2018 will be $35.99, a slight increase from the 2017 conversion factor of $35.89. Reflected in the CY 2018 conversion factor is a -0.03 percent budget neutrality adjustment for relative value unit (RVU) changes and a -0.19 adjustment due to the misvalued code target recapture amount. CMS estimates the proposals contained in the rule will have an overall impact of -1 percent adjustment on urology services under the PFS for CY 2018. 

Amended PQRS, EHR and Value Modifier Policies

In 2016, PQRS program policy required clinicians to report 9 clinical quality measures across 3 National Quality Strategy domains or be subject to a 2.0 negative payment adjustment in 2018. In the rule, CMS proposes to reduce the PQRS reporting requirement to only 6 measures to align with the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program. Similar changes are proposed for the clinical reporting requirements under the Medicare Electronic Health Record (EHR) Incentive Program. CMS also proposes to reduce the automatic VM payment adjustment from -4.0 percent to -2.0 percent for clinician groups of 10 or more, and from -2.0 percent to -1.0 percent for solo and groups with less than 10 clinicians. The AUA, along with the members of the Regulatory Relief Coalition, aggressively pursued relief of the penalties pursuant to these programs through meetings with the office of the Health and Human Services (HHS) Secretary Tom Price, MD and CMS. In light of these efforts, CMS has issued a Request for Information (RFI) to solicit public feedback on solutions to better achieve transparency, flexibility, program simplification and innovation to inform future regulatory actions related to the PFS. 

Proposed CY 2018 Work RVUs for New, Revised and Potentially Misvalued Codes

CMS identified CPT code 52601 (Transurethral Electrosurgical Resection of Prostate) on a screen of potentially misvalued codes and is proposing to reduce the work RVU for CY 2018. In October 2016, the CPT Editorial Panel deleted CPT Category III code 0438T and created a new CPT code 55X87 (Transperineal placement of biodegradable material, peri-prostatic, single or multiple injection(s), including image guidance, when performed). For CY 2018, CMS proposes the following RVU changes for new and existing urology services:

Evaluation and Management Codes

CMS is seeking public comment for updates to Evaluation and Management Codes (E/M) codes, particularly for the history of present illness and physical examination components for E/M office visits.

Telehealth Services

For CY 2018, CMS proposes to add several new codes to the list of telehealth services for low dose computed tomography eligibility, interactive complexity, health risk assessment, care planning for chronic care management and psychotherapy for crisis. 

Appropriate Use Criteria

CMS proposes to delay implementation of the Medicare Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging until 2019 to allow time for clinicians to focus on and adjust to the Quality Payment Program. Earlier this year, the AUA joined several other medical societies in a joint statement calling for Congress to postpone implementation of the Medicare Appropriate Use Criteria (AUC) Program until overlap in the Quality Payment Program has been identified. The AUA also co-sponsored an American Medical Association House of Delegates resolution in June seeking delayed implementation. 

The proposed rule will be published in the Federal Register on July 21, 2017. CMS will accept comments on the proposed rule until September 11, 2017. The AUA will continue to review the proposed rule and prepare comments. More details on the proposed rule are available in the CMS fact sheet.

Click to Expand

Click to Expand