The Associate CIO for one of the top medical schools in the country was telling me about the challenge he faces as a physician and CIO: "Either I can remember these large volumes of information about my specialty, or I can remember the payer rules that come in equally large tomes. But I can't remember both."
Today, CMS publishes in the Federal Register its 834 page proposed rule on Medicare Part B 2009 physician fee schedules and other changes. Comments are due before you're back from vacation... on August 29. The final rule is scheduled for November 1. For those of you with only enough time for the "Cliff Notes version", check out the CMS fact sheet.
First the good news:
Medicare is proposing new HCPCS codes supporting follow-up inpatient telehealth consultations. The codes would be used by practicioners who are "consulted by the patient’s attending physician regarding the patient’s care but who are not available for a face-to-face encounter."
This rule proposes a fairly narrow application of "virtual visits", but it certainly represents a step in the right direction. In 2006, CMS had stopped coverage for these telehealth consultations.
CMS has been resistant to approving codes for any "virtual visits". CMS could serve as a market mover for private insurance, should this regulation be approved.
And now the bad news:
980,000 physicians, other practioners and medical suppliers will be paid an average 5.4% less - - $54 billion in 2009 compared to $57 billion in 2008.
Physician Reporting Quality Initiative (PQRI):
The 1.5% incentive payment for reporting PQRI measures is eliminated. Quality reporting would be extended in 2009 with addtion of 64 new measures and the carry-forward of 111 existing measures.
Electronic Health Record (EHR) Reporting of PQRI
CMS wants to begin accepting data from EHRs for PQRI individual measures (not Measures Groups) starting January 1, 2009.
Exception for Incentive Payment and Shared Savings Programs
Medicare and private insurers have been piloting pay-for-performance and other programs that use economic incentives to encourage quality cost-effective care delivery. In many of these cases, hospitals may be paying physicians and this "may implicate the physician self-referral law". CMS proposes an exception to the physician self-referral law that would permit these payments provided "specified conditions are met."
For providers submitting Part D presecriptions electronically, computer-generated faxes will continue to be permitted if there are temporary communication problems that preclude the use of the NCPDP SCRIPT standard. This is now extended to include dispensers who may also use computer-generated faxes to request refills from providers not capable of using NCPDP SCRIPT.
There are a variety of other actions in the proposed rule with less direct impact on healthcare technology. These include anti-markup provisions, RVU review, Physician Payment Locality Options review, quality standards for diagnostic testing services, ESRD facility payment, competitive acquisition program (CAP) revisions, changes to enrollment and billing rules, beneficiary signatures for non-emergency ambulance service, commentary on organ retreival services .