Regulatory update july 2016 by steven lash

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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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