CMS

CMS Proposed Rule - Beware, Take Notice & Be Heard

This and past weeks, the @NSCHBC listserve has been booming with comments about CMS-1693, the proposed rule that includes Pros and Cons, but PHYSICIANS and PATIENTS alike, need to be aware of what may be possibly on the horizon come January 2019.  A colleague of mine, @Chris Zaenger, said it best with the words below.

I am hopeful about this country and where we will end up. There is much that is good in the proposed rules that will lower the audit risk and documentation burdens on the physician.

NYU announced this week that its Medical School tuition will be FREE going forward indefinitely. A endowment supports this move. Will others follow? Incurring $200-$400K+ in debt for a profession and the daunting prospect of being in your mid 40’s before it is paid off is a tremendous deterrent to the selection of the profession, particularly the lower paying specialties.

American Association of Medical Colleges

The United States will face a shortage of between 40,800 and 104,900 physicians by 2030, according to a new study commissioned by the AAMC. Released March 14, 2017, the study found that the numbers of new primary care physicians and other medical specialists are not keeping pace with the demands of a growing and aging population.

“There is going to be a significant workforce shortage under all of the likely projections. We see that, quite frankly, only getting worse as the population ages,” said Janis M. Orlowski, MD, AAMC chief health care officer.

NOW – will you, the Medicare–covered patient, be able to get in to see a physician on an out-patient basis? Will your physician choose to close their practice to new Medicare patients?

Will your physician become increasingly disgusted with paying employees to battle insurance companies for what is due them? Will physicians and their employees get tired with patients who only want the physical because there is no co-pay when they need medical services to treat their conditions?

Will your physician do as so many others have done, retire early, become employed in a health system where your office visits and treatments are much more costly? Will your physician leave the profession for another? Will they continue to discourage their children from entering a profession where pay is significantly lower that many others and as a physician is likely to be human and make mistakes and get sued for it.

Are you, the patient, already having a hard time getting in to see your physician or to see a specialist?

Medicare is proposing to pay less to your physician in the future when they already only pay a subsistence rate that barely covers the cost of running a practice. Uncle Sam needs to prove they care about the future of the country's people and increase the healthcare budget for at least as long as it takes to cover the baby-boomer bubble. Education of your grandchildren is another subject for a later time (Thank you NYU).

So now @CMS wants to pay less for a sick visit and not pay for it at all if the doctor removes a skin tag or sutures a cut.

For the mission driven physician still in it who care about your health, this is not greed, it is survival….

Tell your patients THIS.

Then ask them to voice their opinion on www.regulations.gov, through AARP or any avenue will listen.

Just because it is CMS, and you might be a non-Medicare or non-Medicaid practice, do not disregard this message … it will affect you as well.

This proposed rule making may be the most dramatic change in policy since 1995.

There is much to share, but, in my opinion, there is ONE IMMEDIATE ISSUE that DEMANDS YOUR ATTENTION.

I have heard some client complaints and seen some evidence that UHC and Independence Blue Cross has been reducing reimbursement by paying 50% for services with the -25 modifier. CMS is proposing to do this as well.  More commercial payors will follow.

How many times do you or does your practice place a modifier 25 on and E&M service when providing a second service (a procedure, a physical, etc.) on the same day. Often done for patient convenience, so they do not have to return again, and for physician efficiency; CMS is proposing to reduce reimbursement by 50% (the national equivalent of $47-$68 on a sick visit encounter). This reduction model was initially introduced and has only been applied to surgical procedures when multiple procedures are performed during the same surgical event. The impact of this change on physician office-based and outpatient-based practices will be dramatic.

The National Society of Certified Healthcare Business Consultants highly suggests you comment with your opinions and recommendations to CMS and Congress.

The comment period expires September 10, 2018,

If you disagree with the CMS proposed rule, I urge you to do the following:

1. Go to www.regulations.gov.

2. Click on “Federal Register” (FR)

3. Reduce the search by filtering using “CMS 1693”

4. Look for the Physician Fee Schedule FR dated July 27, 2018 and click the “COMMENT” button.

Single issue comments will have more impact.

NPPES 3.0 - The NPI Enumeration System

Reprinted with permission from Part B News and DecisionHealth
Surrogates particularly will have an easier time with the NPPES step in the provider enrollment process thanks to recent changes.
On May 15, 2017, CMS’ National Plan and Provider Enumeration System – NPPES, the registry through which providers get and maintain their national provider identifier (NPI) numbers -- went to version 3.0. According to David Zetter, president of Zetter Healthcare Management Consultants in Mechanicsburg, Pa., who was a beta-tester for the new version, NPPES now allows surrogates to access both NPPES and PECOS for all the providers they represent with the same log-in.