Policy & Regulation News

Top Six Proposed Physician Fee Schedules, Payment Policies

By Jacqueline DiChiara

- The healthcare industry awaits the possibility of great financial policy adjustment in the immediate future due to a continuous stream of announcements from The Centers for Medicare & Medicaid Services (CMS) regarding various proposed rules on payment policy and Medicare physician fee schedules.

Physician Fee Schedules

To simplify the abundance of information within the recently announced series of proposed rulings, here is a brief summary of six primary policy changes and fee schedule information.

CMS-1622-P: Medicare payment rate policy changes

CMS issued a recent proposed ruling announcing possible policy changes for Medicare payment rates for skilled nursing facilities (SNFs). Through an objective aimed to improve how the healthcare industry manages its finances, the proposed rule supports the enactment of a value-based pay model for SNFs with quality metrics affecting 2018 reimbursements. CMS anticipates SNF cumulative payments will increase by $500 million, up 1.4 percent from the current year.

“We encourage stakeholders to utilize health information exchange and certified health IT to effectively and efficiently help providers improve internal care delivery practices, support management of care across the continuum, enable the reporting of electronically specified clinical quality measures (eCQMs), and improve efficiencies and reduce unnecessary costs,” states the proposed rule.

CMS-1624-P: inpatient rehabilitation facility PPS

CMS issued a recent proposed rule summarizing updated Medicare prospective payment policies and rates for the Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) and the IRF Quality Reporting Program (IRF QRP). Payment rates would be updated for discharges occurring on or after October 1, 2015 and on or before September 30, 2016, as required by the Social Security Act. CMS proposes to update the IRF PPS payments for next year to reflect a projected 1.9 percent increase factor. The largest payment increase in anticipated as a 2.7 percent increase for rural IRFs within the East North Central region.

CMS also proposes the adoption of an IRF-specific market basket reflecting the cost structures of only IRV providers, phasing in the revised wage index changes, and making revisions and updates to various quality measures and reporting requirements under the IRF QRP.

CMS-1627-P: inpatient psychiatric facilities PPS

CMS proposes updates to payment rates for Medicare inpatient hospital services provided by inpatient psychiatric facilities (IPFs), freestanding IPFs and psychiatric units of an acute care hospital or critical access hospital (CAH).

The proposed rule additionally advocates for a new IPF-specific market basket, an update to the IPF labor-related share, a transition to new Core Based Statistical Area (CBSA) designations within the IPF PPS wage index, phasing out rural adjustments for certain IPF providers, and new IPF quality reporting measures.

CMS-1632-P: inpatient and long-term care

CMS and the Department of Health and Human Services (HHS) propose updates and revisions to the Medicare hospital inpatient prospective payment systems (IPPS) for both operating and capital-related costs of acute care hospitals. The primary initiative is to implement change regarding various statutory provisions, including the Affordable Care Act, the Pathway for Sustainable Growth Reform (SGR) Act of 2013, and the Protecting Access to Medicare Act of 2014.

CMS and HHS also propose updates to the rate-of-increase limits for certain hospitals excluded from IPPS. Additional updates to payment policies and to annual PPS payment rates for inpatient hospital services are slated for upcoming discussion and review. Further examination of quality reporting from specific providers, such as acute care hospitals, participating in Medicare and the Medicare Electronic Health Record (EHR) Incentive Program may occur with the possibility of new requirements or the revision of current requirements.

CMS-2333-P: mental health parity rule

CMS recently announced a proposed rule to grant low-income beneficiaries improved access to both mental health and substance use disorder benefits through either the managed care organization or another service delivery system. 

CMS’ initiative regarding draft regulations “is an important step in an ongoing conversation about how best to integrate behavioral health treatment into the rest of the health care system,” the National Association of Medicaid Directors (NAMD) says in a responding statement.

CMS-2392-P: extend $3B Medicaid eligibility and funding

CMS issued a recent proposed ruling to extend access to enhanced federal financial participation for Medicaid eligibility and enrollment (E&E) systems beyond the initially established deadline of December 31, 2015. CMS’ financial contribution of $3B aims to aid the implementation and upgrading of state Medicaid enrollment systems. The proposed rule additionally plans to update current Medicaid Management Information Systems (MMIS) conditions and standards.

According to CMS’ proposed rule, "Without ongoing enhanced federal funding, state Medicaid eligibility and enrollment systems are likely to become out of date and would not be able to coordinate with, and further the purposes of, the overall mechanized claims processing and information retrieval systems."