American Society of Plastic Surgeons
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FEDERAL | ASPS Comments on 2018 Physician Fee Schedule Proposal

In a letter to the Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma, ASPS commented on several key areas of concern regarding the Physician Fee Schedule (PFS) Proposed Rule, which was published on July 21, 2017. The Society highlighted concerns with a plan to update the documentation and billing requirements for Evaluation and Management services as well as the introduction of new modifiers to report "patient relationships." ASPS asked the Agency to work closely with plastic surgeons to ensure that the new policy does not further burden members in documenting the history, exam and clinical decision-making processes used during a patient's visit.

The CMS proposal also included a plan to implement a "voluntary" program where modifiers will be used to designate five different levels of provider responsibility for a given patient. ASPS noted the duration of the voluntary reporting period was not defined and restated that any attempt to capture this type of data should include sufficient time for analysis and robust feedback before making the program mandatory. The Society also pointed out that terms used to define the levels of responsibility will have different meanings to different physicians, with extensive testing and training necessary to ensure all providers use the indicators the same way. ASPS strongly encouraged CMS to work with the Workgroup for Electronic Data Interchange (WEDI) to investigate alternative solutions for patient relationship reporting at the claim versus line-item level.

While not mentioned in this proposed rule, ASPS reiterated its concerns with the Agency's plan to verify accurate valuation of 10- and 90-day global services. Effective July 1, 2017, the 2017 Final Rule included a plan to collect data on the number of post-operative visits via a claims-based data collection process for a sub-set of surgeons based on a designated subset of surgical CPT codes. Given the underlying weaknesses of capturing post-op visit information via a claims-reporting mechanism, ASPS reiterated its plea to CMS to eliminate this reporting requirement as soon as possible.

With less than three months remaining in CY 2017, the Agency has yet to produce high-value data to date. With that in mind, the Society requested that the Agency develop a data validation process to ensure the accuracy of the information it is collecting and publicly inform stakeholders that it will not attempt to use the data collected for purposes of code revaluation until the validity and accuracy of the data can be confirmed.

Following the current comment period, the Physician Fee Schedule final rule should be published in mid-November.

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