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2015 Medicare Physician Fee Schedule Proposed

The Centers for Medicare and Medicaid Services (CMS) has released the 2015 Medicare Physician Fee Schedule proposed rule and it contains some potentially troubling provisions for plastic surgeons.

The proposed rule includes the elimination of all 10- and 90-day global surgical codes, opting to move to all 0-day surgery codes. The 0-day codes would include only services performed on the day of the surgery. Other pre- and post-operative visits that are deemed medically necessary would then be billed separately.

There is little additional guidance in the proposed rule as to how the global codes would be broken down or as to how some of the services in the global packages will be valued as individual codes. CMS proposes to eliminate 10-day codes by 2017 and 90-day codes by 2018.

Additionally, the proposed rule includes the elimination of the perioperative care measures group and two chronic wound care measures from reporting for the Physician Quality Reporting System (PQRS). If these codes are to be removed, it will be even more difficult for plastic surgeons to appropriately report to PQRS. This is an immediate concern as 2015 begins the penalty phase for not reporting to PQRS. Previously, physicians were eligible for small positive payment adjustments for reporting but beginning in 2015 and after, physicians not reporting to PQRS will receive a negative 2% payment adjustment.

The proposed rule also elaborates more on the implementation of the Value Based Payment Modifier, a budget neutral program that assess physician quality and costs. CMS has set the negative adjustment rate at up to 4% for not meeting the standards. Physicians who do meet the quality and cost standards are eligible for positive payment adjustments.

ASPS will be providing comments on the proposed rule to CMS, emphasizing the potential harmful impact some of these proposals will have on plastic surgeons.

The final rule will be released in November.