Medicare proposed rules will lead to plenty of comments throughout the summer
June 13, 2017
By Jill Rathbun
The fiscal year 2018 Medicare Fee Schedule Proposed Rules have started to be released for comment. Here is a preliminary “scorecard” to help you navigate the 2018 Proposed Rule cycle over the summer and be ready to prepare comments:
Hospital Inpatient Prospective Payment System
On April 14, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update 2018 Medicare payment and polices when patients are admitted into hospitals. Comments are due on June 13, 2017.
The proposed increase in operating payment rates for general acute care hospitals paid under the IPPS that successfully participate in the Hospital Inpatient Quality Reporting (IQR) Program and are meaningful electronic health record (EHR) users is approximately 1.6 percent. CMS projects that the rate increase, together with other proposed changes to IPPS payment policies, will increase IPPS operating payments by approximately 1.7 percent, and that proposed changes in uncompensated care payments will increase IPPS operating payments by an additional 1.2 percent for a total increase in IPPS operating payments of 2.9 percent.
Other additional payment adjustments will include continued penalties for excess readmissions, a continued 1 percent penalty for hospitals in the worst performing quartile under the Hospital Acquired Condition Reduction Program and continued upward and downward adjustments under the Hospital Value-Based Purchasing Program. CMS projects that total Medicare spending on inpatient hospital services, including capital, will increase by about $3.1 billion in FY 2018.
In addition to the payment and policy proposals, CMS is releasing a Request for Information to welcome feedback on positive solutions to better achieve transparency, flexibility, program simplification and innovation. This will inform the discussion on future regulatory action related to inpatient and long-term hospitals.
Quality Payment Program/Medicare Access and CHIP Reauthorization Act of 2015 Year 2
This proposed rule is in the final stages of clearance at the Office of Management and Budget (OMB) and will contain the proposed requirements for physician participation and reporting in the Merit-Based Incentive Payment System (MIPS) and in Advanced Alternative Payment Models. It will discuss quality measures, cost measures, clinical improvement activities and use of electronic health records by physicians. These requirements will include proposed scoring systems and how penalties and bonuses will be apportioned. This proposed rule should be published no later than early June and will have a 60-day comment period.
Physician Prospective Payment System
Around July 4, CMS will issue a proposed rule that updates payment policies, payment rates and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after Jan. 1, 2018. This proposed rule could have several new physician fee schedule policies. It will also address misvalued services and it will have proposed payment changes on codes that have been evaluated for 2018. Payments are based on the relative resources typically used to furnish the service.
Relative value units (RVUs) are applied to each service for physician work, practice expense and malpractice. These RVUs become payment rates through the application of a conversion factor, updated each year as specified in the statute. This proposed rule will also have a 60-day comment period and comments usually are due right after Labor Day.
Hospital Outpatient Prospective Payment System
Also, right around July 4, CMS will release the Calendar Year (CY) 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System policy changes, quality provisions and payment rates proposed rule.
Again, this year, a key proposal will be the continued implementation of Section 603 of the Bipartisan Budget Act of 2015, which will impact how Medicare pays for certain items and services furnished by certain off-campus outpatient departments. There may also be proposals regarding payment policies on the packaging of services and the continued use of comprehensive APCs. CMS may also propose new or reconfiguration of the payment classifications for various services. This proposed rule will also have a 60-day comment period and comments usually are due right after Labor Day.
About the author: Jill Rathbun is managing partner at Galileo Consulting Group.