What Do You Think of Medicare's 2019 Physician Fee Schedule?

January 16, 2019

Last fall, the Centers for Medicare & Medicaid Services (CMS) released its 2019 Final Rule for both the Physician Fee Schedule and the Quality Payment Program (which includes MIPS, the Merit-based Incentive Payment Program). In this rule, CMS is holding off on implementing a major overhaul of evaluation and management (E/M) services it had proposed earlier this year, in which billing codes for E/M levels 2 to 5 would be collapsed into one. The new rules will also promote the increased use of telemedicine through use of a virtual check-in code, and it seeks feedback on possible future use of bundled reimbursement for substance abuse treatment.

The delay on adjustments to E/M services has won some praise from medical groups such as the American Medical Association and the American Academy of Neurology. The physician fee rule carries with it changes in electronic health record (EHR) requirements, as well as a path for more physicians who don't see many Medicare patients to participate in MIPS.

However, other groups are not so pleased with the CMS plan. The American Hospital Association and the Association of American Medical Colleges say they will file a legal challenge to the final rule on payment for outpatient care, which aims to pay physicians who practice at hospital-owned off-campus clinics at a rate equivalent to that for physicians in the community who are not affiliated with a hospital, a so-called "site-neutral" fee — thus flattening out what have been higher rates paid to hospital-affiliated clinics.

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