To check out the quick-read review of CMS 2018 updates, click here.
In November 2017, CMS released two new final rules for physicians affected by MACRA. The 2018 Quality Payment Program Final Rule, which went into effect on January 1, 2018, offers important changes to reimbursement for remote care and affects participants in QPP. CMS also released the 2018 Physician Fee Schedule Final Rule, which addresses payment models for Medicare. What’s more, on January 2, CMS also launched a new system for performance data submission for the QPP, significantly streamlining processes for participating clinicians.
Each of these new measures represents the continuing shifts of policies in order to aid physicians in providing the best care possible. “These rules move the agency in a new direction and begin to ease that burden by strengthening the patient-doctor relationship, empowering patients to realize the value of their care over volume of tests, and encouraging innovation and competition within the American healthcare system,” said Seema Verma, CMS administrator, on releasing the 2018 final rules.
Though the thousand-plus page rules can be dense, they offer important opportunities for physicians to take advantage of new reimbursements as they provide patients with alternative care methods and continue to move toward a value-based model.
2018 QPP Final Rule
The QPP, which was created in 2015 as a part of the Medicare Access and CHIP Reauthorization Act (MACRA), is aimed at aiding physicians in the transition to value-based care. A significant change released in the 2018 QPP Final Rule was an upgrade of PGHD to a “high” rating. This offers physicians the opportunity to receive a higher score in the CPIA category for using technology to engage patients. The move by CMS better incentivizes remote care management, as PGHD continues to demonstrate clinical value.
CMS noted the importance of “clinical endorsement” and recognition of PGHD in the context of clinical care. They suggested clinicians incorporate digital tools that offer ongoing assistance for patients outside the doctor’s office. The rule also informs physicians that the use of “passive devices” – those devices unable to transmit PGHD in real time – would not be reimbursed. This means physicians must incorporate active tools that transmit PGHD to the doctor or clinical feedback to the patient — in real time — in order to be reimbursed.
2018 Physician Fee Schedule Final Rule
Effective starting January 1, 2018, CMS unbundled CPT code 99091 under the 2018 PFS Final Rule. This code, which is labeled for the “analysis of clinical data stored in a computer,” was formerly bundled. Bundling requires that the code be used in conjunction with a standard evaluation and management service code, which almost always requires a patient to have an in-person visit.
The unbundling of this code means that physicians will now be reimbursed separately for time spent on the collection and interpretation of remote PGHD, at least 30 minutes at a time. This is a significant change: the unbundling of this code no longer requires an in-person patient visit to reimburse physicians for their time spent on remote care.
The code guidelines mention that the reimbursement will include time accessing, reviewing and analyzing said data, as well as any time spent on communication with the patient or documentation as a result of the analysis. Additionally, the reimbursement is not restricted by some of the more structured telehealth or in-person guidelines for care, meaning there is room for flexibility in the technology and the way technology is used by physicians and patients to generate and transmit the PGHD. With over 150,000 apps and devices available to patients and able generate health data, this intentional opening in the guidelines makes it easier for physicians to get data from patients via their preferred platform.
The move incentivizes physicians to spend more time interpreting and offering care based on data they receive from their patients remotely; reimburses them for activities they may have already been conducting; and, does not require in-person appointments, which can be costly and burdensome for both the provider and the patient. Now, more comprehensive and long-term remote care programs can be rewarded for appropriately incorporating PGHD to improve patient outcomes.
QPP Data Submission Updates
Last week, CMS also launched a new system which streamlines the submission of 2017 performance data for clinicians. In the past, QPP-participating clinicians were required to use multiple systems or tools to submit their performance data, which can be burdensome for physicians and could result in missed opportunities for reimbursement. The new system is available on the QPP website and allows physicians to log into one portal to submit all their data and fulfill all MIPS requirements, which significantly streamlines the process for participants. CMS also called for continuing feedback on the data submission process, as they plan to continue to improve based on the feedback they receive from participants.
What these changes suggest for the future of RPM
The unbundling of CPT code 99091 and the upgrade of PGHD use to a “high” rating are just first steps in expanding the use of remote care, and this idea is largely supported by CMS comments during their release of the rules.
In a switch to value-based care, it is crucial physicians are rewarded for implementing new measures — like remote care — that streamline care practices while improving patient outcomes and lowering costs. New changes in QPP codes demonstrate that CMS understands the importance of such recognition. Physicians can take advantage of these updates in order to push innovation forward and capitalize on programs that offer better efficiencies, outcomes, and costs.
To learn more about the changes implemented in the 2018 PFS and QPP Final Rules, read more here.
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