AAPM&R Submits Comments to CMS for Medicare Physician Fee Schedule

October 2, 2017

On September 11, 2017, your Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) Physician Fee Schedule proposed rule. The proposed rule reflects CMS’ recommendations regarding payment and policy for physician services effective January 1, 2018. AAPM&R commented on several proposals that may impact members, including some changes to payment.

• Coverage for Telehealth and Remote Monitoring Services: CMS is accepting comments on telehealth coverage, including expanding coverage for remote monitoring services. Your Academy supported a proposal to cover remote monitoring paid under code 99091, which describes the collection and interpretation of physiologic data. CMS currently considers 99091 to be a bundled service and does not separately pay for it. We recognize that remote collection of physiologic data is becoming more and more pervasive in medicine. CPT^® code 99091 currently specifies ECG, blood pressure and glucose monitoring as examples of the types of data that can be reviewed under this code. However, the Academy expects that many other types of data, such as mobility and function, will eventually be available remotely.
• Changes to Payment for Physiatry Services: CMS proposed changes to payment for five codes billed by physiatry.
  • 64418 – Injection, anesthetic agent; suprascapular nerve. CMS proposes to approve the AMA RUC’s recommendation to reduce the work RVU for this service from 1.32 wRVUs to 1.10 wRVUs. This code was reviewed by the RVS Update Committee (RUC) in April 2016; it was the first time this code underwent RUC review since it was valued in the mid-1990s. 
  • 64553 – Percutaneous implantation of neurostimulator electrode array; cranial nerve and 64555 – peripheral nerve. CMS proposes to approve significant increases to the work RVUs for these codes. The RVUs for 64553 will increase from 2.36 wRVUs to 6.13 wRVUs and 64555 will increase from 2.32 wRVUs to 5.76 wRVUs. As with 64418, these services had not been reviewed since the mid-1990s. These services are now done in a much more complicated way due to advances in technology and were therefore valued significantly higher by the RUC and subsequently CMS.
  • 76881 – Ultrasound, extremity, nonvascular; complete and 76882 – limited. CMS proposes to approve revised practice expense values for these codes. For the complete ultrasound, CMS proposes decreasing practice expense RVUs from 2.69 PE RVUs to 0.44 PE RVUs and for the limited ultrasound, CMS proposes increasing practice expense RVUs from 0.49 PE RVUs to 2.11 PE RVUs. In our comment letter, AAPM&R has highlighted the negative impact these changes will have on our members and on patient care.
• Evaluation and Management Services: CMS is accepting comments on the administrative burden on the current E/M guidelines and associated documentation requirements. AAPM&R recognizes that administrative burden related to documentation has increased for members, especially as EHR technology has become more pervasive. In our comments to CMS, we highlight the need for CMS to conduct a systematic review of E/M, including widespread physician involvement prior to making any changes. 
• Appropriate Use Criteria for Advanced Diagnostic Imaging Services: CMS has proposed that ordering clinicians begin consulting appropriate use criteria prior to ordering applicable advanced diagnostic imaging effective January 1, 2019. In our comment letter to CMS, your Academy has proposed delaying implementation of these requirements until clinicians have had more time to understand the relevant reporting requirements. 

CMS will finalize 2018 payment and policy in a final rule anticipated for release in November. Your Academy will continue to keep you informed regarding payment and policy changes via www.aapmr.org and Connection, your AAPM&R members-only e-newsletter.