2010 MPFS Sees Significant Policy Changes
By now, you’ve probably heard about the biggest change the 2010 Medicare Physician Fee Schedule (MPFS) final rule has brought about—the elimination of consultation codes. Because this news has received so much fanfare, you may have overlooked other important policy changes. The following is a summary of additional significant policy changes taking place in 2010 of which you should be aware.
In the 2010 MPFS proposed rule, the Centers for Medicare & Medicaid Services (CMS) proposed to include the data collected by the American Medical Association’s (AMA’s) Physician Practice Information Survey (PPIS) into the calculation of resource based practice expense relative value units (PE RVUs) without a transition period.
In the final rule, CMS finalized this change but decided the impact of using the new PPIS data warranted a four-year transition. Note, however, that this transition applies to only 2009 CPT® codes. New and substantially revised CPT® codes are not subject to this transition.
CMS intends to continue to use the oncology supplemental survey data for drug administration codes.
Equipment Utilization Rate
CMS finalized the proposal to increase the equipment utilization rate from 50 percent to 90 percent for expensive diagnostic equipment priced at more than $1 million. This change will also be transitioned over a four-year period, and excludes therapeutic equipment.
Geographic Practice Cost Indices
The legislative 1.0 work geographic practice cost index (GPCI) floor established by the Medicare Improvements for Patients and Providers Act (MIPPA) of 2008 expired Dec. 31, 2009. The 2010 GPCIs do not include the 1.0 floor.
The 2010 MPFS final rule establishes the update to malpractice relative value units (RVUs). For 2010, malpractice costs by providers of technical component (TC) services will be based on malpractice premium data for independent diagnostic testing facilities (IDTFs) instead of medical physicist premium data.
Initial Preventative Physical Exam
CMS is revising the work RVUs for the Initial Preventative Physical Exam (IPPE) or “Welcome to Medicare” visit, as proposed in the 2009 MPFS proposed rule, from 1.34 to 2.30.
In the 2009 MPFS final rule, new CPT® code 95992 Canalith repositioning procedure(s) (eg, Epley maneuver, Semont maneuver), per day was bundled with evaluation and management (E/M) codes. After the final rule was published, CMS realized that physical therapists performing this service had no way to bill for it since they cannot bill for E/M services.
In the 2010 MPFS final rule, CMS changed the indicator for 95992 to I (Invalid). Physicians will continue to be paid for this service as part of an E/M service. Physical therapists should continue to use one of the more generally defined “always therapy” CPT® codes.
Audiology Code Clarification
Also in the 2010 MPFS final rule, CMS clarifies that therapeutic and/or management activities are not payable to audiologists because they do not fall under the diagnostic tests benefit category designation.
For 2010, CMS will pay 55 percent of the approved amount for outpatient psychiatric services. Previously, Medicare paid 50 percent of the approved amount for outpatient mental health treatment services, while paying 80 percent of the approved amount for outpatient physical health services. Section 102 of the MIPPA gradually phases out the limitation by 2014. When the provision is fully implemented, CMS will pay outpatient mental health services at the same level as other Part B services.
Note: An emergency update of the 2010 MPFS data base was issued Dec. 23, 2009.