MPFS proposed rule touches on Smart Dose compliance, updated values

CMS continued its busy month this week by releasing a proposed rule for changes related to the 2016 Medicare Physician Fee Schedule (MPFS). The announcement comes just a week after CMS published the proposed rule for updates to the hospital outpatient prospective payment system (HOPPS).

This is the first MPFS update since the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was signed into law in April, replacing the sustainable growth rate (SGR) with 0.5% payment increases in physician reimbursements from now until 2019. Here's some of the highlights from the MPFS proposal:

Tracking Smart Dose Compliance: The rule proposes a new modifier that will be used to track CT systems that do not apply under the new XR-29-2013 standard, also known as Smart Dose CT. Medicare will pay 5% less for scans performed on noncompliant systems in 2016, and 15% less in 2017. The HOPPS proposed rule included a similar provision.

Equipment-Related Updates: Back in 2012, CMS recognized that it may have valued some codes related to radiation therapy incorrectly, and this proposed rule includes some updated utilization rate assumptions. Based on input from the American Medical Association (AMA) and the Relative Value Scale Update Committee (RUC), this rule proposes that the linear accelerators are used approximately 35 hours per week instead of 25 hours per week. This change would be implemented over two years.

In addition, CMS proposes that the price for a PACS workstation be changed to $5,557 after looking over submitted invoices. The current price is $2,501.

CDS: The proposed rule defined some terms related to the process of accessing appropriate use criteria through clinical decision support (CDS) systems and built a foundation for the future development of several processes related to CDS systems.

Lung Cancer Screening: CMS proposed that lung cancer screening will be valued at 1.02 Relative Value Units (RVUs), because it’s equal in time and intensity to non-contrast chest CT. The ACR notes in its own summary of the rule that it has already argued, and will continue to argue, against this decision.

“The value should be higher due to the various registry and quality requirements within the National Coverage Determination,” the ACR said.

PQRS & MIPS: CMS also proposed that the 2018 Physician Quality Reporting System (PQRS) payment adjustment match the 2017 payment adjustment. Those failing to correctly report data on PQRS quality measures will be hit a with a -2% payment adjustment in 2018.

After 2018, of course, PQRS will cease to exist altogether after it and other payment programs are consolidated into the Merit-based Incentive Payment System (MIPS) in 2019, yet another change brought on by MACRA.

CMS noted that it is especially interested in feedback related to MIPS and other aspects of MACRA. A Request for Information will be sent out later this year with questions covering a wide range of topics.

Much more information is included in the rule, and CMS included many resources on its website. Comments about the rule will be accepted until Sept. 8, 2015. A final rule is expected on or around Nov. 1, 2015.