2016-07-18 21:05:23 UTC

In-Depth Analysis of Proposed 2017 Medicare Rules

July 18, 2016

We've summarized the key provisions of the Physician Fee Schedule and HOPPS/ASC proposed rules.

CMS released the calendar year (CY) 2017 Medicare Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rules. These annual rules establish payment rates and policies for the next calendar year.   

AGA, ASGE and ACG have developed summaries of key provisions in the proposed rules to help GI practices prepare for the payment and policy changes that take effect Jan. 1, 2017.

Major Provisions in the CY 2017 Medicare Physician Fee Schedule Proposed Rule Payment Policy 

  • As previously reported, CMS has proposed values for new moderate sedation codes, removing the associated value from the majority of endoscopic procedures. For those who provide their own moderate sedation, there will be no impact on physician work. Those who use anesthesia professionals will see a reduction in physician work relative value units (wRVU) and office practice expense for the majority of GI endoscopy procedures. 
  • CMS proposes to maintain the value of anesthesia services furnished in conjunction with upper (CPT 00740) and lower (CPT 00810) endoscopy services for 2017. However, given the significant change in the relative frequency with which anesthesia codes are reported with colonoscopy services (more than 50 percent of the time for several types of colonoscopy procedures), CMS believes the relative values of these anesthesia services should be reexamined. 

Read more about proposed 2017 PFS changes in the summary prepared by the GI societies.
Review our 2017 PFS payment analysis for GI

Major Provisions in the CY 2017 HOPPS/ASC Payment System Proposed Rule

  • CMS proposes two conversion factors to update ASC payment using the consumer price index: one for ASCs meeting quality reporting requirements of a positive 1.2 percent adjustment, and one for ASCs not meeting quality reporting requirements of a negative .8 percent adjustment.  
  • CMS proposes additional modifications to the restructured Ambulatory Payment Classifications (APCs) for GI procedures that would move the biopsy codes for esophagoscopy, colonoscopy through stoma and colonoscopy into the higher payment Level 2 APC group while leaving EGD, ERCP and flexible sigmoidoscopy in the lower payment Level 1 APC group with the base codes.  
  • Instead of a full year of reporting, CMS extends the 90-day electronic health record (EHR) reporting period in 2016 for all returning participants of the EHR Incentive Program.  
  • ASC Quality Reporting (ASCQR) Program: ASCs are subject to a reduction of 2 percent for failure to successfully participate in the ASCQR program. Seven new measures are proposed for CY 2017.

Read more about HOPPS/ASC changes in the summary prepared by the GI societies.
Review our 2017 HOPPS analysis for GI.
Review our 2017 ASC analysis for GI

AGA, ACG and ASGE will comment together on the proposed rules. Comments are due Sept. 6, 2016. 

More on Medicare incentive/penalty programs

Help Medicare Make Coverage Policy

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Quality Payment Program Reporting for 2018 Raises the Bar

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But, there's still time to avoid a payment penalty for the 2017 reporting year.

CMS Releases 2018 Medicare Payment Rules

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Tri-Society Regulatory Summary for Members of AGA, ACG and ASGE