FINAL CY 2012 POLICY, PAYMENT CHANGES IN THE MEDICARE PHYSICIAN FEE SCHEDULE
The Centers for Medicare & Medicaid Services (CMS) issued a final rule with comment period on Nov. 1, 2011 that updates payment policies and Medicare payment rates for services furnished by physicians and nonphysician practitioners (NPPs) that are paid under the Medicare Physician Fee Schedule (MPFS) in calendar year (CY) 2012. The final rule addresses Medicare public comments on payment policies that were described in two separate proposed rules earlier this year—the Five-Year Review of Work Relative Value Units under the Physician Fee Schedule (published in the Federal Register on June 6, 2011) and the Medicare Program; Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2012 (published in the Federal Register on July 19, 2011). The final rule also addresses interim final values established in the CY 2011 MPFS final rule with comment period (published in the Federal Register on Nov. 29, 2010). In addition, the final rule assigns interim final values for new and revised codes, as well as for potentially misvalued codes, for CY 2012 and requests comments on these values. Finally, the final rule addresses comments on requirements for signatures on requisitions for clinical laboratory services.
This fact sheet discusses the provisions in the CY 2012 MPFS final rule affecting payment policies and payment rates. The policies relating to the Physician Feedback Reports and Value-based Modifier, Electronic Health Records Incentive Program, and the Physician Quality Reporting System, are addressed in separate fact sheets.
Since 1992, Medicare has paid for the services of physicians, NPPs and certain other suppliers under the MPFS, a system that pays for covered physicians’ services furnished to a person with Medicare Part B. Under the MPFS, a relative value is assigned to each of more than 7,000 types, of services to capture the amount of work, the direct and indirect (overhead) practice expenses and the malpractice expenses typically involved in furnishing the service. The higher the number of relative value units (RVUs) assigned to a service, the higher the payment. The RVUs for a particular service are multiplied by a fixed-dollar conversion factor and a geographic adjustment factor to determine the payment amount for each service furnished.
Provisions INCLUDED IN THE CY 2012 MPFS FINAL RULE WITH COMMENT PERIOD
CMS is applying several changes to the GPCIs as a result of additional analyses conducted both in accordance with the Affordable Care Act and commitments made in the CY 2011 final rule with comment period. For CY 2012, CMS will use the Bureau of Labor Statistics Occupational Employment Statistics specific to the offices of physicians industry to calculate the PE employee GPCI. In addition, CMS is replacing the U.S Department of Housing and Urban Development rental data as the proxy for physician office rent with rent data from the 2006-2008 American Community Survey. Lastly, CMS is creating a purchased service index to account for the labor-related industries within the “all other services” and “other professional expenses” Medicare Economic Index (MEI) categories. These changes result in very little change to the GPCIs and indicate that the data CMS has used to adjust for geographic variation is consistent and accurate. However, the expiration of the statutory provisions in the Affordable Care Act and the Medicare and Medicaid Extension Act will result in some payment reductions in the areas that benefitted from them in 2010 and 2011.
CMS is also basing the GPCI cost share weights on the revised and rebased 2006 MEI finalized by OACT in the CY 2011 final rule with comment period. CMS opted not to adopt the 2006-based MEI for GPCI cost share weights in the 2011 final rule in response to public comments. CMS has subsequently addressed many of these commenters concerns’ in this CY 2012 final rule through the changes that are described above.
The Institute of Medicine (IOM) also has been evaluating the accuracy of the geographic adjustment factors used for Medicare physician payment. A supplement to their first report, released in September, 2011, includes an evaluation of the accuracy of geographic adjustment factors for the GPCIs and the methodology and data used to calculate them. CMS is already implementing some of the IOMs recommendations through the revisions to the GPCIs adopted in this final rule with comment period and is analyzing whether other recommendations should be adopted in the future. However, some IOM recommended revisions to the GPCIs would require a change in law.
imaging services to consecutive body areas from 25 to 50 percent for the second and subsequent imaging procedures performed in the same session. The MPPR policy currently applies only to the technical component (TC). For CY 2012, CMS is applying the MPPR to the professional component (PC) of certain diagnostic imaging services. The procedures with the highest PC and TC payments would be paid in full, but the PC payment will be reduced by 25 percent for subsequent procedures furnished to the same patient, by the same physician or group practice, in the same session on the same day. The final rule policy reduces payments for these services by approximately $50 million which would be redistributed to other services paid under the MPFS
The final rule with comment period will appear in the Nov. 28, 2011, Federal Register. CMS will accept comments on those provisions that are subject to comment until Jan. 3, 2012, and will respond in the MPFS for CY 2013.
For more information, see:
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