29 Nov CMS Final Rule
As you likely know, the CMS FINAL RULE 2019 has been published. As always, there is much hype and fanfare that seem to come along each July with the Proposed CMS Rules and each November with the Final CMS Rules. Although the largely publicized proposal to restructure the E/M codes was not implemented in the final rule this year, we’ve prepared a summary of a few, minor changes for radiation oncology.
The estimated overall impact from the 2019 Final CMS Medicare Physician Fee Schedule to physicians practicing in a hospital-based environment and billing professionally is expected to be an increase of 1% on Medicare payments.
The estimated overall impact from the 2019 Final CMS Medicare Physician Fee Schedule to physicians practicing in a free-standing center and billing globally is expected to be a decrease of 2% on Medicare payments.
EVALUATION AND MANAGEMENT OUTCOMES
- For FY2019, E/M reimbursement will not change.
- Changes for E/M service payment are likely to be addressed in FY2021.
- The conversion factor increased from 35.99 to 36.04.
- Treatment delivery codes for IMRT will increase by 1%.
- Treatment delivery codes for EBRT will decrease by 3%.
- There will not be an additional code that can be billed to encompass the work involved in planning and management of superficial cases (77401).
- The MIPS program will continue to contain the same four components as in previous years: Quality, Promoting Interoperability, Improvement Activities and Cost.
- Measure 156 (Radiation Dose Limits to Normal Tissue) will be removed from the Radiation Oncology Measures group. At this time, it appears that the other three measures (102,143,144) will remain alone in the group.
- Low volume threshold for MIPS eligibility will continue to be 200 Medicare Part B individual patients per year.
- For those providers who perform 75% or more of their services in a hospital setting, the Promoting Interoperability exemption will remain.
- There continues to be a push towards and Advanced Payment Model for Radiation Oncology, as CMS sites that “radiation oncology is a promising area of healthcare for bundled payments.” We will continue to monitor and inform you on this initiative.