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Volume 13, Issue 4 Download for iPad

2019 Medicare Final Rules

Each year around July, the Centers for Medicare and Medicaid Services (CMS) publishes proposed rules for the next year’s Medicare Physician Fee Schedule (PFS) and Outpatient Prospective Payment System (OPPS) describing proposed changes to the amounts and factors used to determine Medicare payment rates. The proposed rules are published in the Federal Register (FR) and have a comment period of at least 60-days. After reviewing all comments received, CMS develops and publishes the final rules (usually released at the end of October or early November), which include a summary of comments received and CMS’ response to significant and relevant issues raised in public comments. 1

The final rules are published in the FR and include a comment period of at least 30-days. The proposed and final rules, as well as the public comments received before the end of the comment period, are available at https://www.regulations.gov. In this issue, we will look at the highlights of the 2019 Medicare final rules.

Medicare Physician Fee Schedule

Medicare Physician Fee Schedule (PFS)1, 2, 3

2019 Conversion Factor

On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that includes updates to payment policies and rates, and quality provisions for services furnished under the PFS on or after January 1, 2019.

Under the PFS, payments are based on the relative resources typically used to furnish the service through the assignment of Relative Value Units (RVUs) to each service for three components: physician work, practice expense, and malpractice. These RVUs are then adjusted by their corresponding Geographic Practice Cost Indices (GPCIs) to account for geographic differences in input prices. Finally, the RVUs are turned into payment rates through the application of a conversion factor (CF), the CF is the number of dollars assigned to an RVU. 4

CF

The CF is updated annually and in 2019 will be $36.0391, a slight increase above the calendar year (CY) 2018 PFS conversion factor of $35.9996.  The 2019 CF reflects adjustments based on budget neutrality and includes a 0.25% update, as required by the Bipartisan Budget Act of 2018, before applying the 2019 RVU Budget Neutrality Adjustment of -0.14%. 2019 is the final year of the CF updates that were mandated through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

Calculation of the Calendar Year (CY) 2019 PFS Conversion Factor

CY 2018 Conversion Factor

 

35.9996

Statutory Update Factor

0.25 percent (1.0025)

 

CY 2019 RVU Budget Neutrality Adjustment

-0.14 percent (0.9986)

 

CY 2019 Conversion Factor

 

36.0391

Source: PFS 2019 Final Rule Table 92

In the Medicare PFS final rule, CMS provides estimates on the payment impact on PFS services, by specialty, due to the policies finalized in the rule. As a reminder, the specific patient and payer mix of services provided could result in a different impact on Medicare payments from that shown in Table 94 of the final rule. CMS estimates an impact of -1% for hematology/oncology, radiation oncology & radiation therapy centers, -2% for independent labs, -5% for diagnostic testing facilities and 0% impact to rheumatology.

TABLE  94—CY 2019 PFS ESTIMATED IMPACT ON TOTAL ALLOWED CHARGES BY SPECIALTY


Specialty

Allowed Charges in Millions

Impact of Work RVU Changes (%)

Impact of PE RVU Changes (%)

Impact of MP RVU Changes (%)

Combined Impact (%)

Diagnostic Testing Facility

734

0

-5

0

-5

Hematology/Oncology

1,741

0

-1

0

-1

Independent Lab

646

0

-2

0

-2

Radiation Oncology & Radiation Therapy Centers

1,765

0

0

0

-1

Rheumatology

541

0

0

0

0

Source: PFS 2019 Final Rule Table 94

Evaluation & Management (E/M) Documentation Changes Finalized for CY 2019, 2020, and 2021 3, 5

CMS Responds to Comments Received

In the 2019 proposed PFS rule, CMS proposed extensive changes to the documentation, coding and payment of E/M services. Among the proposed changes was the proposal to collapse the payment rates from the current five-tier E/M service to one payment rate for level 1 office and outpatient visits, and one blended payment rate for level 2-5 office and outpatient visits. As proposed, the national unadjusted payment rate for E/M levels 4 and 5 for new patients would drop from the 2018 rate of $167 and $172, respectively, to a blended payment rate of $134 in 2019.  CMS provided the rationale that minimizing complex documentation requirements would reduce the administrative burden on providers and thus justify the lower payment rate for levels 4-5 E/M services.

On August 27, 2018, the American Medical Association (AMA), And about 170 medical groups sent a letter to Administrator Verma, supporting CMS’ “Patients Over Paperwork” initiative, and the goal of reducing administrative burdens for physicians and other health care professionals. The medical groups expressed support for several of the documentation policy changes proposed and opposed the proposal to collapse payment rates for the eight office visit services for new and established patients saying the proposal could be detrimental to health care professionals who treat the sickest patients. In the sign-on letter, the groups voiced support for the AMA’s creation of a workgroup of physicians and other health professionals who would be tasked with analyzing the E/M coding and payment issues and to develop solutions to be presented to CMS in time for implementation in the 2020 Medicare PFS. 6

According to Seema Verma, CMS Administrator, CMS received 15,000 comments on their proposal to update documentation requirements and change the model of payment for E/M services.7 In response to the comments received, CMS ultimately finalized some of the E/M documentation requirements beginning CY 2019, and delayed and revised the implementation of the coding and payment changes to E/M services until CY 2021.

E/M Documentation Changes

E/M Documentation Changes Finalized for CY 2019 and CY 2020

For CY 2019 and CY 2020, CMS continues the current coding and payment structure for E/M office/outpatient services. As such, providers will continue to document based on either the 1995 or 1997 documentation guidelines.

For CY 2019 and beyond, CMS finalized the following policies:

  • History and Exam – for established patients, providers are only required to focus on what has changed since the last visit or pertinent items that have not changed. Providers should review prior data, update as necessary, and indicate in the medical record that they have done so;
  • Chief Complaint and History - for both new and established patients, practitioners may review and verify chief complaint and history entered by ancillary staff or the beneficiary. Practitioner would indicate in the medical record that they reviewed and verified this information;
  • Elimination of the requirement to document the medical necessity of a home visit in lieu of an office visit; and
  • Removal of potentially duplicative requirements for notations in medical records that may have previously been included in the medical records by residents or other members of the medical team for E/M visits furnished by teaching physicians.

E/M Payment, Coding, and Documentation Changes Finalized for CY 2021

Beginning in CY 2021, CMS will implement payment, coding, and additional documentation changes including the following finalized policies:

  • Reduction in the payment variation for E/M office/outpatient visit levels by paying a single rate for E/M office/outpatient visit levels 2 through 4 for established and new patients while maintaining the payment rate for E/M office/outpatient visit level 5 in order to better account for the care and needs of complex patients;
  • Permitting practitioners to choose to document E/M office/outpatient level 2 through 5 visits using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines, or alternatively practitioners could continue using the current framework;
  • Beginning in CY 2021, for E/M office/outpatient levels 2 through 5 visits, CMS will allow for flexibility in how visit levels are documented— specifically a choice to use the current framework, MDM, or time. For E/M office/outpatient level 2 through 4 visits, when using MDM or current framework to document the visit, CMS will also apply a minimum supporting documentation standard associated with level 2 visits. For these cases, Medicare would require information to support a level 2 E/M office/outpatient visit code for history, exam and/or medical decision-making;
  • When time is used to document, practitioners will document the medical necessity of the visit and that the billing practitioner personally spent the required amount of time face-to-face with the beneficiary;
  • Implementation of add-on codes that describe the additional resources inherent in visits for primary care and particular kinds of non-procedural specialized medical care, though they would not be restricted by physician specialty. These codes would only be reportable with E/M office/outpatient level 2 through 4 visits, and their use generally would not impose new per-visit documentation requirements; and
  • Adoption of a new “extended visit” add-on code for use only with E/M office/outpatient level 2 through 4 visits to account for the additional resources required when practitioners need to spend extended time with the patient.

New Add-On Codes for Use Only with Level 2-4 E/M Office/Outpatient Visits

GCG1X New Primary Care Complexity Code: Visit complexity inherent to evaluation and management associated with primary medical care services that serve as the continuing focal point for all needed health care services (Add-on code, list separately in addition to level 2 through 4 office/ outpatient evaluation and management visit, new or established).

GCG0X New Non-procedural Specialty Care Complexity Code: Visit complexity inherent to evaluation and management associated with non-procedural specialty care including endocrinology, rheumatology, hematology/oncology, urology, neurology, obstetrics/gynecology, allergy/immunology, otolaryngology, interventional pain management, cardiology, nephrology, infectious disease, psychiatry, and pulmonology. (Add-on code, list separately in addition to level 2 through 4 office/outpatient evaluation and management visit, new or established).

GPRO1 New Extended Visit Code: Extended time for evaluation and management service(s) in the office or other outpatient setting, when the visit requires direct patient contact of 34-69 total face-to-face minutes overall for an existing patient or 38-89 minutes for a new patient (List separately in addition to code for level 2 through 4 office or other outpatient Evaluation and Management service).

The existing prolonged services code may be used with E/M visit level 5. CPT code 99354: Prolonged evaluation and management or psychotherapy service(s) (beyond the typical service time of the primary procedure) in the office or other outpatient setting requiring direct patient contact beyond the usual service; first hour (List separately in addition to code for office or other outpatient Evaluation and Management or psychotherapy service).

The table below illustrates the projected payment amounts (based on 2019 payment rates) for CY 2021 with the blended payment rate for E/M levels 2-4 and the addition of the new add-on codes or the existing prolonged services code.

 

2018 Payment Rate

Revised Payment Amount 2021***

 

CPT Level

Visit Code Alone (2018 Payment Rate)

Visit Code Alone Payment (Blended Payment)

Visit Code with Either Primary or Specialized Care Add-on Code**

Visit Code with New Extended Services Code (Minutes Required to Bill)

Visit Code with Both Add-on and Extended Services Code Added**

Current Prolonged Code Added (Minutes Required to Bill) *

New Patient 99202-99205

Level 2

$76

$130

$143

$197
(at 38 minutes)

$210

 

Level 3

$110

Level 4

$167

Level 5

$211

$211

 

$344 (at 90 minutes)

Established
Patient
99212-99215

Level 2

$45

$90

$103

$157
(at 34 minutes)

$170

 

 

Level 3

$74

Level 4

$109

Level 5

$148

$148

 

$281 (at 70 minutes)

*This is not a new code. The current prolonged service code, describing 60 minutes of additional time but billable after 31 minutes of additional time, is only billed approximately once per one thousand visit codes reported. It is paid at approximately $133. Physician groups have routinely complained to CMS that billing prolonged with any regularity tends to prompt medical review and is ultimately cost-prohibitive.
**In cases where one could bill both the primary and specialized care add-on, there would be an additional $13. ***The dollar amounts included in this projection are based on 2019 payment rates; actual amounts in 2021 when the policy takes effect will differ.

Source: CMS.gov. E&M Payment Chart.
www.cms.gov/sites/drupal/files/2018-11/11-1-2018%20EM%20Payment%20Chart-Updated.pdf

Although CMS finalized these CY 2021 payment and coding changes in the 2019 PFS Final Rule, they also state that they intend to continue discussions with the public and may further refine the CY 2021 policies.

Same-Day Visits by Practitioners of the Same Group

CMS solicited comments on eliminating the Medicare Claims Processing Manual’s policy that prevents Medicare from reimbursing providers for same-day visits with multiple clinicians in the same specialty within a group practice unless there is documentation that the visits were for unrelated problems. CMS received many comments and will consider the issue further in future rulemaking.

New Communication Technology Codes Finalized for CY 2019

New Communication Technology CodesThe new communication technology codes G2012 and G2010 establish Medicare payment for virtual visits to determine if an in-person visit is necessary.

G2012 (Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or  procedure within the next 24 hours or soonest available appointment; 5–10 minutes of medical discussion). The Medicare national payment amount for G2012 is $14.78 for non-facilities and $13.33 for facilities.

G2010 (Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with verbal follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.) The Medicare national payment amount for G2010 is $12.61 for non-facilities and $9.37 for facilities.

CMS’ decision to pay for the new communication technology codes G2012 and G2010 is significant, historically CMS considered routine non-fact-to-face communication that occurs before or after an in-person visit to be bundled into the payment for the visit. In finalizing the proposal to pay separately for these services, CMS acknowledges the advances in communication technology and the patients’ and providers’ adoption of the virtual check-in services. Further, CMS says that appropriate use of virtual check-ins may mitigate the need for potentially unnecessary office visits.

In the final rule, CMS summarizes definitions and billing rules for these services. In defining the technology that is used for G2012, CMS said they will allow “audio only real-time telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission.” Furthermore, the interaction must be directly between the patient and the billing provider and is limited to established patients.

G2012 and G2010 are not separately payable if the service originated from a related E/M service provided within the previous 7 days or leads to an E/M service or procedure within the next 24 hours or soonest available appointment, in those cases the payment is considered bundled into the payment for the E/M visit or procedure. CMS declined to replace the language stating “next available appointment” with a time-based window. CMS expressed their desire to allow for clinically appropriate flexibility and recognizing that beneficiary convenience is also a factor when appointments are scheduled.

CMS also declined to apply a frequency limitation for CY 2019, saying they want to make sure that the service is appropriately utilized when a patient needs a brief non-face-to-face check-in to assess whether an office visit is necessary.

A patient co-payment will apply to these services and the patient’s consent for the service is required and should be noted in the medical record. In the final rule, CMS states they are requiring beneficiary verbal consent that is noted in the medical record for each billed service for HCPCS G2012, and beneficiary consent that could be verbal or written, including electronic confirmation that is noted in the medical record for each billed service for HCPCS code G2010.

Interprofessional Telephone/Internet/Electronic Medical Record Consultation Services – Finalized CY 2019

CMS referenced the changes in medical practice and technology in their decision to change the procedure status of CPT codes 99446-99449 from B (bundled) to A (active). Effective January 1, 2019 these services are separately payable by Medicare.

CPT codes 99446-99449 provides reimbursement for consultation between practitioners provided via telephone, internet or EHR. Cost sharing will apply to these codes and they require verbal consent from the beneficiary that is noted in the medical record for each service. These services may only be billed by practitioners that can independently bill Medicare for E/M visits.

Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a verbal and written report to the patient’s treating/requesting physician or other qualified healthcare professional:

  • 99446:  5–10 minutes of medical consultative discussion and review. Medicare national payment amount for 2019 is $18.38
  • 99447: 11–20 minutes of medical consultative discussion and review. Medicare national payment amount for 2019 is $36.40
  • 99448: 21–30 minutes of medical consultative discussion and review. Medicare national payment amount for 2019 is $54.78
  • 99449 31 minutes or more of medical consultative discussion and review. Medicare national payment amount for 2019 is $72.80

CMS also finalized their proposal to pay separately for CPT codes 99451 and 99452, these services also require the patient’s verbal consent that is noted in the medical record for each interprofessional consultation service:

  • 99451: Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified healthcare professional, 5 or more minutes of medical consultative time. Medicare national payment amount for 2019 is $37.48
  • 99452: Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional 30 minutes. Medicare national payment amount for 2019 is $37.48

Misvalued Codes – Phase-in

CMS continues to phase-in the reductions to drug administration codes identified as misvalued in 2017. The reductions were implemented in 2018 but reductions are limited to a maximum of 19% per year. The phased-in drug administration changes in 2019 include:

  • 96374 Injection IV Push (19%)
  • 96375 Injection IV add-on (16%)
  • 96360 Hydration IV infusion initial (19% in 2019; 7% in 2020)
  • 96372 Injection sc/im (19% in 2019; 6% in 2020)

Multiple Procedure Payment Reduction (MPPR) Not Finalized

CMS did not finalize their proposal to apply a MPPR reduction of 50% to services provided on the same day as a separately identifiable E/M visit by the same physician (or physician in the same group practice) for the same patient.

New Part B Drugs and WAC – Finalized CY 2019

New Part B Drugs and WACCMS finalized their proposal to adjust the add-on payment for new Part B Drugs paid through Wholesale Acquisition Cost (WAC) methodology.

New drugs coming to market are paid at WAC pricing during the first quarter as they have no established Average Sales Price (ASP). In 2018, new drugs paid under the WAC methodology were paid at WAC + 6%. For CY 2019, CMS finalized their proposal to lower the WAC add-on to WAC + 3%.

In finalizing the policy, CMS stated their belief that the scope of the payment changes are modest and will affect few drugs. Furthermore, CMS said, “the overhead for many new drugs and biologicals is not likely to be significantly higher than the overhead for existing Part B injectable drugs, the add-on is based on an undiscounted list price that tends to be higher than market prices, and many new drugs and biologicals are expensive, thus we do not expect a significant effect on providers’ margins.”

The WAC + 3% payment rate does not include payment reductions due to sequestration.

Site Neutral Payments Finalized CY 2019

For 2019, CMS maintains the current PFS relativity adjuster for non-excepted items and services provided by non-excepted off-campus provider-based departments (PBDs), under which CMS pays 40% of the outpatient prospective payment system amount.

CMS states that the PFS relativity adjuster provides greater payment alignment between outpatient care centers and encourages fairer competition between hospitals and physician practices. This adjustment will be maintained for future years until updated data or other considerations indicate that an alternative adjuster or change is warranted.

Appropriate Use Criteria (AUC) Program

The AUC program requires physicians to consult with AUC through a qualified clinical decision support system for advanced diagnostic imaging services. The AUC program will be mandatory beginning January 1, 2020 with voluntary participation available through December 2019.

For 2019, CMS finalized the revision of the significant hardship criteria in the AUC program to include:

  • Insufficient internet access;
  • Electronic health record (EHR) or clinical decision support mechanism (CDSM) vendor issues;
  • Extreme and uncontrollable circumstances.

CMS finalized their proposal to add independent diagnostic testing facilities (IDTFs) to the definition of applicable setting under the AUC program, to more consistently apply it to outpatient settings.

CMS also finalized the policy to allow AUC consultations, when not personally performed by the ordering professional, to be performed by clinical staff under the direction of the ordering professional. CMS specified that the clinical staff should have a level of knowledge that allows for effective communication of advanced diagnostic imaging orders, interaction with AUC, and engagement with the ordering professional, while they remain under the direction of the ordering professional.

MEDICARE OUTPATIENT PROSPECTIVE PAYMENT SYSTEM (OPPS) FINAL RULE 8,9

OPPS

CMS finalized a positive update of 1.35% for payments under the OPPS. CMS estimates this increase will result in an increase in expected total payments of $5.8 billion over estimated payments made in 2018.

Calculation:

   2.9% market basket increase
   -0.8% adjustment for multi-factor productivity (MFP)
   -0.75% adjustment required by law
   1.35% Update

Clinic Visit Service

CMS finalized their proposal to apply a Physician Fee Schedule (PFS)-equivalent payment rate for the clinic visit service (G0463, Hospital outpatient clinic visit for assessment and management of a patient) when provided at an off-campus provider-based department (PBD) that is paid under the OPPS. The reduction in the payment for the clinic visit service will be phased in over two years and is estimated to result in a $380 million savings in 2019.

In the final rule, CMS reiterates that capping the OPPS payment rate at the PFS equivalent rate will control the volume of the unnecessary increases in certain services because the payment differential that is driving the site-of-service decision will be removed.

Clinical Families of Services at Excepted Off-Campus Provider-Based Departments (PBDs) of a Hospital

In the proposed rule, CMS proposed that if an excepted off-campus PBD furnishes a service from one of 19 proposed clinical families of services that it did not furnish during a baseline period (November 1, 2014 through November 1, 2015) those services would be paid under the PFS rather than be covered under the outpatient department (OPD) fee schedule. CMS did not finalize this proposal for CY 2019 but stated their concern that “hospitals may be able to purchase additional physician practices and add those physicians to existing excepted off-campus PBDs.” CMS said they will continue to monitor the expansion of services in excepted off-campus PBDs and may propose to adopt a limitation on the expansion of services in future rulemaking.

340B Drug Payment Policy

The final rule extends the 340B drug payment methodology adopted in CY 2018 for hospital departments paid under OPPS. Additionally, CMS finalized the policy to pay for separately payable biosimilars acquired under the 340B program at the ASP -22.5% of the biosimilar's own ASP, rather than ASP -22.5% of the reference product's ASP.

CMS also finalized their proposal to pay average sales price (ASP) minus 22.5% for 340B-acquired drugs furnished by non-excepted, off-campus provider-based departments (PBDs) that are paid under the Physician Fee Schedule. CMS will continue to exempt rural sole community hospitals, children’s hospitals, and certain cancer hospitals. CMS states that expanding the 340B payment rate at ASP -22.5% to non-excepted PBDs would avoid the perverse incentives for hospitals to acquire drugs and biologicals under the 340B Program and avoid Medicare payment adjustments that account for the discount by providing these drugs to patients predominantly in nonexcepted off-campus PBDs.

CMS says the reduction in the payment rate will also lower the cost of drugs and biologicals to Medicare beneficiaries and to more equitably ensure that the beneficiaries benefit from the discounts provided through the 340B program.

Late Breaking News - Federal Judge Halts the 340B Drug Payment Reductions 10

In a ruling issued December 27, 2018, U.S. District Judge Rudolph Contreras ruled that the Centers for Medicare and Medicaid Services (CMS) exceeded its authority when it reduced the Medicare payment rates for 340B drugs from ASP +6% to ASP -22.5%.

The court ordered the plaintiffs, the American Hospital Association (AHA) and America’s Essential Hospitals, and CMS to provide supplemental briefings on the issue of remedies.

1 Regulations.Gov Regulatory Timeline. https://www.regulations.gov/docs/FactSheet_Regulatory_Timeline.pdf. Accessed December 1, 2018.

2 CMS.gov. Fact Sheet Final Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2019. https://www.cms.gov/newsroom/fact-sheets/final-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year. Accessed November 23, 2018.

3 govinfo.gov. Federal Register Volume 83, Number 226 Friday, November 23, 2018. Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; Medicaid Promoting Interoperability Program; Quality Payment Program--Extreme and Uncontrollable Circumstance Policy for the 2019 MIPS Payment Year; Provisions From the Medicare Shared Savings Program--Accountable Care Organizations--Pathways to Success; and Expanding the Use of Telehealth Services for the Treatment of Opioid Use Disorder Under the Substance Use-Disorder Prevention That Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act; Final Rules and Interim Final Rule. https://www.govinfo.gov/content/pkg/FR-2018-11-23/html/2018-24170.htm. Accessed November 23, 2018.

4 CMSgov. MLN Fact Sheet Medicare Physician Fee Schedule. https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/medcrephysfeeschedfctsht.pdf. Accessed November 23, 2018.

5 govinfo.gov. Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program. https://www.govinfo.gov/content/pkg/FR-2018-07-27/pdf/2018-14985.pdf. Accessed Saturday, July 28, 2018.

6 AMA Press Releases.  170 Groups Send Letter on Proposed Changes to Physician Payment Rule.
https://www.ama-assn.org/press-center/press-releases/170-groups-send-letter-proposed-changes-physician-payment-rule. Accessed November 1, 2018.

7 www.cms.gov. Clinician Letter Reducing Burden Documentation and Coding Reform.  https://www.cms.gov/About-CMS/Story-Page/Clinician-Letter-Reducing-Burden-Documentation-and-Coding-Reform-.pdf. Accessed November 10, 2018.

8 CMS.gov. Hospital Outpatient Prospective Payment – Notice of Final Rulemaking with Comment (NFRM). https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HospitalOutpatientPPS/Hospital-Outpatient-Regulations-and-Notices-Items/CMS-1695-FC.html. Accessed November 21, 2018.

9 CMS.gov. Fact Sheet: CMS finalizes Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System changes for 2019 (CMS-1695-FC). https://www.cms.gov/newsroom/fact-sheets/cms-finalizes-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center. Accessed November 21, 2018.

10 United States District Court for the District of Columbia Memorandum Opinion. DENYING DEFENDANTS’ MOTION TO DISMISS; GRANTING PLAINTIFFS’ MOTION FOR A PERMANENT INJUNCTION; DENYING AS MOOT PLAINTIFFS’ MOTION FOR A PRELIMINARY INJUNCTION
 https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2018cv2084-25. Accessed December 28, 2018.

 

Published by Rise Marie Cleland.Sponsored by Lilly Oncology

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ABOUT THE EDITOR
Risė Marie Cleland is the Founder and CEO of Oplinc, Inc., a national organization of oncology professionals. Through Oplinc, Inc., Ms. Cleland publishes the weekly Oplinc Fast Facts focusing on the timely dissemination of information pertaining to billing, reimbursement and practice management in the oncology office and Oplinc’s Best Practices Review, which provides a more in-depth look at the issues and challenges facing oncology practices. Ms. Cleland also works as a consultant and advisor for physician practices, pharmaceutical companies and distributors.

IMPORTANT NOTICES
Please note that this newsletter is presented for informational purposes only. It is not intended to provide coding, billing or legal advice. Regulations and policies concerning Medicare reimbursement are a rapidly changing area of the law. While we have made every effort to be current as of the issue date, the information may not be as current or comprehensive when you review it. Please consult with your legal counsel for any specific reimbursement information. For Medicare regulations visit: www.cms.gov.

CPT® is a Trademark of the American Medical Association Current Procedural Terminology (CPT) is copyright 2019 American Medical Association. All Rights Reserved. No fee schedules, basic units, relative values, or related listings are included in CPT. The AMA assumes no liability for the data contained herein.

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