American Society of Plastic Surgeons
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New Year, New Medicare Payment Policies

CMS final rules recently went on display updating payment polices for services furnished in a physician office or in a hospital outpatient setting. These final rules address some of the concerns ASPS and other medical societies raised, while others are yet to be fully addressed. As an example, the Medicare Physician Fee Schedule (MPFS) rule for 2020 includes a proposal that ASPS advocated for, reducing the burden of medical record documentation. Teaching physicians paid under the MPFS will now be able to review and verify new notes, via a signature and date, without having to re-document notes the medical record already includes.

Additionally, ASPS was successful in delaying any changes to the valuation of post-operative visits included in global surgery codes. We expect to continue discussions with the Agency on their plan to assess with any final policy implemented in 2021 the number and level of E&M services delivered in the global period.

ASPS members should also be aware that this Final Rule contains a reinterpretation of Medicare law that previously required physician supervision for all Physician Assistant (PA) services. Beginning in 2020, PAs must continue to perform their services in accordance with state laws and scope-of-practice rules, but for states with no explicit laws or guidance, evidence of the PA's scope of practice and relationship with any supervising physician must be documented and maintained at the practice level, instead of in the medical record of each patient.

In the hospital outpatient setting, ASPS successfully pushed back again this year on proposed changes to reimbursement for skin substitute products. CMS was adamant however, that hospitals begin posting "standard charges" for many of their services – including aesthetic procedures – offered at the hospital. While this requirement is set to become effective on January 1, 2020, the American Hospital Association and several hospital groups have filed a lawsuit, claiming the burden of compliance is enormous, with expected confusion and delays in care as competitors rush to lower prices to match their rivals. There is also concern that this new policy may prompt further consolidation in the commercial health insurance industry. The groups have asked for an expedited decision to prevent Hospitals from needing to comply if the rule is ruled unconstitutional. ASPS has and will continue to work with CMS and other stakeholders on this issue to advance solutions that increase transparency while reducing administrative burdens.

And finally, ASPS members should be aware of new Medicare Prior Authorization policy, set to become effective on July 1, 2020, that will require hospitals to show the medical necessity of blepharoplasty, botulinum toxin injections, panniculectomy and rhinoplasty procedures before Medicare will provide reimbursement. For private practices to obtain prior authorization, medical information will need to be forwarded to the hospital before the procedure can be scheduled. Here again, ASPS will continue to work with CMS to ensure any administrative burdens of this new policy will be minimal.

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