rather than one larger co-payment for the entire 10- or
90-day global service.
The ACS also raised implementation concerns with
transitioning 10- and 90-day to 0-day global codes. For
example, the ACS expressed concern about evaluation
and management (E/M) services that are currently
included in 10- and 90-day global codes, which are different from E/M services that are separately billable
outside of the global period. If surgeons are expected
to substitute separately billable E/M services, they will
not receive reimbursement for all the services that were
previously included in the 10- and 90-day global period.
The Physician Payments Sunshine Act, also known
as Open Payments, requires applicable manufacturers (AMs) of drugs, medical devices, and biologicals to
track payments and other transfers of value to physicians and teaching hospitals and then report these payments to CMS annually. Financial disclosures from the
2013 reporting year were made available to the public
on September 30, 2014, and data for subsequent years
will be available by June 30.
The MPFS final rule eliminates an exemption for
reporting transfers of value made to physicians who
speak at accredited continuing medical education
(CME) program events. The ACS submitted comments
to CMS firmly opposing the elimination of this “bright
line” CME exemption, as it is definitive and feasible
to implement. The ACS comments also discussed the
unintended consequences of this proposal, such as
physicians abstaining from presenting at CME events
and thereby withholding their expertise on ways to
improve the quality and cost of health care and increas-
ing the administrative burden on physicians to track
each transfer of value made to them at accredited CME
events. Unfortunately, CMS has chosen to eliminate
this exemption and will instead apply a separate exemp-
tion for physician speakers at accredited CME events
when a transfer of value is made and the AM is unaware
of the identity of the physician during that reporting
year and for the first half of the following year.
The Physician Quality Reporting System (PQRS) is a
Medicare quality pay-for-reporting program, which
began as a voluntary program that provided payment
incentives to eligible professionals (EPs) who satisfactorily report data on quality measures for covered services furnished during a specified reporting period.
Beginning in 2015, no more incentives will be offered
for the program, and lack of participation will result in
a payment penalty of 2 percent to be applied in 2017. EPs
can report measures for the program through claims,
a traditional registry, electronic health records (EHRs),
or a qualified clinical data registry (QCDR). CMS finalized several key changes for PQRS 2015.
Individual measure reporting
EPs can participate in the PQRS program by reporting on individual measures or, alternatively, on measures groups. For individual measure reporting via
the claims- and registry-based options, CMS requires
the reporting of nine measures covering at least three
National Quality Strategy domains (NQS) for 50 percent of the applicable Medicare Part B fee-for-service
(FFS) patients in order to avoid a payment penalty. Previously, EPs had to report on only three PQRS measures to avoid a penalty.
A new requirement in 2015 for those EPs who have
at least one face-to-face Medicare encounter is that at
least one of the nine measures must be reported from
the 19 cross-cutting measures identified by CMS. In
CMS’ view, cross-cutting measures are broadly applicable to all physician specialties.‡
JAN 2015 BULLETIN American College of Surgeons
2015 MEDICARE FEE SCHEDULE
‡Centers for Medicare & Medicaid Services. Medicare Program; revisions
to payment policies under the physician fee schedule, clinical laboratory
fee schedule, access to identifiable data for the Center for Medicare and
Medicaid Innovation models & other revisions to Part B for C Y 2015 final
rule. Federal Register. 79 (November 13, 2014):67801. Available at: https://
gram-revisions-to-payment-policies-under-the-physician-fee-schedule-clinical-laboratory. Accessed December 1, 2014.