Physicians are aware that the 2017 Medicare Physician Fee Schedule (PFS) Final Rule (“Final Rule”) has been finalized and will take effect Jan. 1, 2017. Among items in the Final Rule which physicians should find important are as follows:
- The RVU conversion factor has been set at $35.887, which represents an increase of approximately 24% from 2016.
- Medicare has made important changes to reduce the administrative burden of chronic care management (CCM) to encourage greater utilization. As an example, there is no longer a requirement for written consent for patient enrollment (although the patient still needs to be advised of the service which needs to be documented in the EHR). Medicare beneficiaries are not required to have access 24/7 to the care plan as a condition of payment.
- Medicare continues to expand telehealth coverage, with the PFS addressing end stage renal disease related services for dialysis, advanced care planning services, and critical care consultations furnished via telehealth. This coverage uses new Medicare G-codes.
- Billing codes have been revised to pay for primary care, care management, and other cognitive specialties. This includes payments to primary-care practices that use multi-disciplinary professionals for care management resources to treat patients with behavioral health conditions.
- Physicians should review the changes that have occurred related to the federal physician self-referral prohibition, commonly known as “Stark.” The Final Rule has expanded the codes covered under Stark, which can be found at http://www.cms.gov/medicare/fraud-abuse/physicianselfreferral/list_of_codes.htmlwww.cms.gov/medicare/fraud-abuse/physicianselfreferral/list_of_codes.html.
In reviewing the list physicians should note services for which federal patients are self-referred which may now be covered under Stark. If so, this may require a review of the practice’s referral relationships, lease arrangements and even the compensation arrangements within the practice. The new codes appear to be primarily in the areas of physical therapy, occupational therapy, radiology (particularly, mammography and PET), and certain screening tests.
- The Final Rule establishesa limitation on the types of “per-unit of service” compensation formulas from 2009 that may be used for determining office space and equipment rental charges. Medicare has restated its requirement that rental charges for the lease of office space or equipment may not use a formula based on per-unit of service rental charges, to the extent that such charges reflect services. More info by Steven Lash.