July 18, 2017

On July 13, 2017, the Centers for Medicare & Medicaid Services (CMS) released the 2018 Medicare Physician Fee Schedule Proposed Rule. The rule proposes changes to payment for and policies related to physician services for calendar year 2018. AAPM&R is in the process of reviewing the proposed rule in detail, including analyzing the rule’s proposed impact on payment rates for PM&R services in 2018. We have already identified several highlights that will be of interest to Academy member:

• CMS is proposing an increase to the conversion factor, which is the dollar amount used by Medicare to calculate rates for services. The conversion factor is proposed to increase from $35.8887 to $35.9903; an increase of just over $0.10. 
• CMS predicts that changes recommended in the proposed rule will have an overall 1% positive impact on payment for Physical Medicine services. The impact of the rule on payment for individual services may vary.
• CMS has proposed accepting revised relative value units (RVUs) for three PM&R codes (see chart below) based on recommendations made by the AMA RUC. AAPM&R participates in the AMA RUC process and presents survey data from practicing physicians to help support fair valuation of PM&R services.

• CMS is soliciting stakeholder comments and recommendations regarding a revision to the current Evaluation and Management coding guidelines.  Current guidelines date from 1995 and 1997 and arguably do not reflect current medical practice including changes in technology, documentation practices and workflow. CMS recognizes that changes may need to be made to the requirements for physical examination and patient history. 
• CMS has proposed moving forward with the creation of HCPCS Level II modifiers to designate patient relationship categories.  Clinicians will be able to report these modifiers on a voluntary basis beginning January 1, 2018.  CMS expects that accurate use of the modifiers, which are mandated under MACRA, will take time.  Therefore, the voluntary collection of modifiers in 2018 is expected to be a learning period for clinicians.

AAPM&R is continuing an extensive review of the proposed rule and will continue to inform members about relevant proposed changes to the physician fee schedule in future announcements and news articles. Furthermore, the Academy will develop comments on the rule to be submitted to CMS by the September 11, 2017 comment deadline.