practitioner) and have a relatively high time threshold.
(The time counted must be an hour or more beyond
the usual service time for the primary or “companion”
E/M code that also is billed.) They are not reported for
time spent in care plan oversight services or other non-face-to-face services that have more specific codes and
no upper time limit in the CPT code set.
In the final rule, CMS agreed that payment for 99358
and 99359 codes would provide a means to recognize
the additional resource costs of physicians and other
billing practitioners when they spend an extraordinary
amount of time outside of an E/M visit performing
work that is related to that visit and does not involve
direct patient contact (such as extensive medical record
review, review of diagnostic test results, or other ongoing care management work).
In addition, CMS indicated its intention to adopt
the CPT code descriptors and prefatory language for
reporting these services, which requires that time
counted toward the codes describe services furnished
during a single day directly related to a discrete face-to-face service that may be provided on a different day.
One caveat is that the services must be directly related
to those furnished in a face-to-face visit. CMS stressed
that these codes are to be used to report extended non-face-to-face time that is spent by the billing physician or
other practitioner (not clinical staff) that is not within
the scope of practice of clinical staff, and that is not
adequately identified or valued under existing codes
or the 2017 new codes.
AUC for advanced diagnostic imaging services
Beginning January 1, 2018, physicians will be
required to report appropriate use criteria (AUC)
through a qualified clinical decision support mechanism (CDSM). The MPFS final rule indicated that
a list of qualified CDSMs will be published by June
30, 2017, at which time some providers will be able
to begin reporting AUC.
The College encouraged CMS to allow physicians
more time to select a CDSM and recommended that
AUC reporting be implemented gradually in the initial years of the program, to allow for transparency
and input from specialty societies. CMS considered the
College’s comments and delayed the requirement for
providers to consult CDSMs from its original January 1,
2017 deadline. The agency said it will direct qualified
provider-led entities to post AUC—along with the process used to develop and modify AUC—online to allow
for stakeholder review.
Corrections to value-based modifier
For 2016, CMS finalized the processes through which
physician groups or solo practitioners may request a
correction of errors related to the value-based payment
modifier (VM) calculation. The 2017 MPFS proposed
rule solicited comments on how to update these VM
informal review policies and establish how the quality
and cost composites under the VM would be affected
if unanticipated issues, such as those involving data
integrity, were to arise. CMS proposed four informal
review policies intended to help individual and group
practitioners reduce uncertainty and better predict the
outcome of their final VM adjustment.
The College urged CMS to give groups and individual practitioners the opportunity to resubmit data when
errors are discovered, and requested that the agency
clarify how it plans to prevent data integrity issues in
the new Quality Payment Program (QPP) outlined in
MACRA. CMS finalized its four informal review policies to modify physicians’ quality and cost composites
based either on an informal review determination or
widespread quality and cost data issues. The agency
addressed the College’s comments and indicated that
quality data issues will be significantly limited moving
forward due to program reporting enhancements.
Starting with the 2017 performance year, the QPP
will combine the existing Medicare meaningful use
2017 MEDICARE PHYSICIAN FEE SCHEDULE
CALCULATION OF THE 2017 MPFS CONVERSION FAC TOR
Conversion factor in effect in 2016 $35.8043
Update factor 0.50 percent ( 1.0050)
2017 RVU budget neutrality adjustment -0.013 percent (0.99987)
2017 target recapture amount -0.18 percent (0.9982)
2017 MPPR adjustment -0.07 percent (0.9993)