American Society of Plastic Surgeons
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CMS: Protect Physician and Facility Payments

Late last month, the Centers for Medicare and Medicaid Services (CMS) released their proposed updates to the Physician Fee Schedule and Quality Payment Program as well as the Hospital Outpatient Prospective Payment System (HOPPS) detailing policy changes for both physicians and facilities for the 2020 calendar year.

Without concessions from CMS, changes to physician reimbursement could include a reduction in the equation used to recognize post-operative visits during the "global surgery" package; supervision requirements for physician assistants: revised rules for teaching physicians and the need for review of medical records; and allowing Anesthesia Assistants to perform pre-operative history and physicals.

To develop a more cohesive, alternative model to the current siloed reporting pathways inherent to its existing Quality Payment Program, CMS has proposed a new model of quality reporting focused on conditions or procedures as an alternative to the extensive reporting under the four components of MIPS. While on the surface this MIPS "valued pathways" program appears to reduce administrative burden, it could further limit the measures available to plastic surgeons. Additionally, proposed changes to MIPS reporting in 2020 could restrict reporting options.

The HOPPS rule also includes proposals to implement prior authorization processes for "high-volume" services and to address the level of supervision necessary for outpatient therapeutic services. The Agency has provided additional information on its plan to require hospitals to make public a list of standard charges.

ASPS has worked with committee members to provide feedback on these proposed rules and will continue to advocate for the specialty, ensuring the fee-setting process remains transparent, does not limit access to care, and policy does not escalate administrative burdens for our members.

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