American Society of Plastic Surgeons
For Consumers

CMS: Amend Physician Fee Schedule Final Rule

ASPS submitted comments last month in response to the Centers for Medicare and Medicaid Services (CMS) Final Rule for the 2019 Physician Fee Schedule. While there were many changes that were beneficial for plastic surgeons including the "Low Volume Threshold Opt-In Policy," which offers smaller providers the opportunity to qualify for positive payment adjustments, there were other requirements that created potential barriers for quality reporting. These included the need to establish benchmarks for new performance measures within their first year; case minimum requirements; removal of topped-out measures that could still be useful; changes to the scoring methodology and most troubling, the mandate that CMS hold licensure of measures developed by any medical society or risk losing approval of their Qualified Clinical Data Registry (QCDR) application for 2019.

CMS explained that holding licensure could reduce the number of duplicative measures and improve harmonization between similar measures. However, ASPS and many other physician membership organizations strongly opposed this action due to the risk of intellectual property violation and the heavy staff and member resources required to develop meaningful performance measures. While CMS rescinded this requirement for the 2019 QCDR applications, they have indicated that they intend to require this in the future.

Since most available performance measures from CMS are tailored to the primary care physician, it is imperative that ASPS continue the development of meaningful performance measures that represent the clinical work of plastic surgeons available within the ASPS TOPS/QCDR. ASPS expects that CMS will need several months to review comments on this Final Rule.