The 2019 Medicare Physician Fee Schedule includes updates to many healthcare policies and programs, including the Quality Payment and Medicare Shared Savings Programs, the Laboratory Fee Schedule, and Physician Self-Referral, to name a few. Comments on the particulars of the final rule are due on December 31, 2018, and the official schedule will go into effect on January 1, 2019.1 As an anesthesiologist, you may be wondering how this new physician fee schedule might affect you.
The national conversion factor for anesthesia services will undergo a slight change when the new schedule comes into effect. The conversion factor will increase under the new schedule from $22.1887 to $22.2730. 1 The Medicare Access and Chip Reauthorization Act (MACRA) initially specified a 0.5 percent conversion factor update for anesthesia services. However, the Bipartisan Budget Act of 2018, which widely increased federal discretionary spending caps, further updated this ruling by including a provision for budget neutrality adjustments that outlined a lower, 0.25 percent updated conversion factor. This small increase in the national conversion factor ultimately allows anesthesiologists to charge higher fees for their services. Beyond anesthesia-specific practices, the more expansive final physician conversion factor will increase from $35.9996 to $36.0391. This physician conversion factor is still relevant to anesthesiologists who are billing for flat fee services. For example, “the use of ultrasound guidance in the placement of a nerve block.” would be considered a flat-fee service for which the physician conversion factor could be applied.2
Revisions made to the Quality Payment Program for 2019 take into account Merit-Based Incentive Payment System (MIPS) performances from 2017. If a clinician is MIPS eligible, their Medicare fee-for-service payments will be based on their MIPS performance from 2017, which will undergo a maximum two percent change after adjusting for budget neutrality.1 MIPS performance is evaluated based on four factors: quality, promoting interoperability (use of information technology), improvement activities, and cost. 3 The MIPS program already includes certified registered nurse anesthetists and will be expanded to include additional clinician categories. Clinicians who are MIPS eligible can choose to be evaluated within certain categories based on activities that best reflect their practice. In addition, an expansion to the low-volume threshold criteria of the Quality Payment Program will enable clinicians to opt out of MIPS if they so choose. According to McDermott Consulting, “Per the 2019 LVT policy, to be excluded from MIPS, clinicians or groups will need to meet one of the following three criteria: have ≤ $90,000 in Part B allowed charges for covered professional services, provide care to ≤ 200 beneficiaries or provide ≤ 200 covered professional services under the PFS.”1 Groups of healthcare professionals or individual practitioners will be able to opt into MIPS if they are not deemed exempt based on all three low-volume threshold criteria.
According to Seema Verma, the Centers for Medicare and Medicaid Services (CMS) administrator, new document requirements will be streamlined under the new fee schedule, allowing clinicians to “put patients over paperwork.”2 These new documentation practices will make the paperwork process smoother by providing multiple options for healthcare practitioners when they approach billing patients. Overall, there are three important points to glean from the new physician fee schedule: first, the conversion factors relevant to anesthesiology practices are set to increase reimbursements, secondly, providers can expect more freedom to choose their level of involvement in the MIPS program, and lastly, regulations for filing claims and other paperwork will become more flexible and efficient.
- Madhani, Sheila, and Mara McDermott. “Top 10 Takeaways: 2019 Medicare Physician Fee Schedule.” McDermott+Consulting, 6 Nov. 2018, mcdermottplus.com/insights/top-10-takeaways-2019-medicare-physician-fee-schedule/.
- Popa, Rachel. “What Anesthesia, Pain Management Providers Should Know about CMS’s 2019 Proposed Payment Rule: 6 Key Points.” Becker’s ASC Review, 23 July 2018, www.beckersasc.com/anesthesia/what-anesthesia-pain-management-providers-should-know-about-cms-s-2019-proposed-payment-rule-6-key-points.html.
- Quality Payment Program, qpp.cms.gov/mips/overview