2012 MPFS Final Rule Cuts Imaging Payments, Redistributes RVUs
The release of the 2012 Medicare Physician Fee Schedule (MPFS) final rule brings an expansion of the multiple procedure payment reduction policy for Medicare, as well as modifications to the Physician Quality Reporting System (PQRS) and other changes.
Congress acted on Dec. 23, 2011 to stall a 27.4 percent cut in Medicare payments that would have gone into affect Jan. 1, 2012. The legislation extends current payment rates for the first two months of 2012, by which time Congress will have to act once again to prevent drastically lower reimbursement for Medicare physicians. A permanent fix to the sustainable growth rate (SGR) formula that determines Medicare payments is widely desired.
As of Jan. 1, a change will be applied to the “multiple procedure payment reduction” to advanced imaging services. When two or more imaging procedures subject to the payment reduction are reported together, reimbursement for the second and subsequent procedures will be reduced 25 percent to account for the duplication of services among the procedures. When the physician demonstrates the medical necessity of furnishing interpretations in separate sessions, modifier 59 Distinct procedural service is appropriate. A list of diagnostic imaging services subject to the multiple procedure payment reduction may be found in Addendum F of the final rule.
Also for 2012, the Centers for Medicare & Medicaid Services (CMS) is changing the reporting period for claims, registry, and electronic health record (EHR)-based reporting for the PQRS to 12 months only. CMS is also finalizing a six‐month reporting period (July 1 through Dec. 31) for reporting measures groups via registry. Eligible professionals (EPs) who satisfactorily report 2012 PQRS measures can qualify for an incentive equal to 0.5 percent of the total estimated part B allowed charges for all covered professional services furnished by the EP (or, for those participating in the group practice reporting option, the group practice) during the applicable reporting period.
Requirements for the e-Prescribing Incentive Program are undergoing similar modifications. The eRx incentive program provides incentive payments to EPs and group practices that successfully e-prescribe. Successful participants are eligible for a 1 percent incentive payment in 2012 and 0.5 percent in 2013. The reporting period for 2012 and 2013 will be Jan. 1 through Dec. 31. CMS will allow only the claims-based reporting mechanism for the six-month 2013 and 2014 payment adjustment reporting periods.
Additional measures in the 2012 MPFS final rule include:
- CMS will retract a policy finalized in the 2011 MPFS final rule that required a physician’s or non-physician practitioner’s (NPP’s) signature on a requisition for clinical diagnostic laboratory tests paid under the clinical laboratory fee schedule (CLFS). CMS is reinstating the prior policy: The physician’s or NPP’s signature is not required on a requisition for a clinical diagnostic laboratory test paid under the CLFS for Medicare purposes.
- CMS continues its effort to establish quality and cost measures, as well as the initial performance period that will be used in establishing a new value-based modifier. The agency plans to hold public events in the next year to gather input on the modifier.
- The Geographic Practice Cost Indices (GPCIs), used to determine final Medicare payments to physicians according to the geographic area in which they practice, will be modified for 2012. The portion of the GPCIs allotted to physician work will be lowered, while the portion of practice expense and employee compensation will rise.
- CMS finalized a proposal to evaluate its list of potentially misvalued code initiative by focusing on high-volume and dollar codes billed by physicians to determine whether these codes are over-valued. These codes were selected for review because they have not been reviewed for at least six years.