CMS to implement Congressional action on SGR fix
Congress has agreed to a one-year reprieve from the 26.5 percent physician Medicare payment cut that was scheduled to begin on Jan. 1, 2013. This action fixes the sustainable growth rate (SGR) through the end of 2013.
Additionally, Congress agreed to fix another component of the formula intended to reflect geographic differences in the costs of resources needed to produce physician services. However, Congress did not make any changes to the practice expense and work relative values contained in the 2013 Medicare physician fee schedule.
Therefore, even with these Congressionally mandated changes, dermatologists can expect to see reductions in 2013 in Medicare payments for some procedures (such as some complex repair codes and surgical pathology), whereas other payments may increase slightly (such as with laser treatments).
The Centers for Medicare and Medicaid Services (CMS) has advised that it is currently revising the 2013 Medicare physician fee schedule to reflect the one-year SGR fix, as well as technical corrections that were identified after the final rule was published in November. The 2013 conversion factor is $34.0230.
In an effort to provide enough time to revise the fee schedule, CMS is allowing Medicare claims administration contractors to hold Medicare claims with January 2013 dates of service for up to 10 business days (through Jan. 15, 2013). CMS expects that these claims will be released into processing no later than Jan. 16, 2013.
Additionally, the 2013 Annual Participation Enrollment Program period has been extended. Eligible physicians, practitioners, and suppliers can change their Medicare participation status through Feb. 15, 2013. Participation elections and withdrawals must be post-marked on or before Feb. 15, 2013; the effective date for participation status changes elected by providers during the extension remains Jan. 1, 2013.
Dermatology practices are advised to submit claims based upon guidance from their Medicare contractors. Read more from CMS. For more information, email your specific questions to firstname.lastname@example.org.
View the 2013 Medicare Physician Fee Schedule here.
The Centers for Medicare and Medicaid Services (CMS) released the 2013 physician fee schedule final rule on Nov. 1, 2012. The AADA’s advocacy efforts, including members’ engagement in valuation surveys, mitigated the cuts to dermatology in this rule. Read the full text of the final rule here. Read the AADA comment letter on the 2013 physician fee schedule final rule.
Visit the CMS Physician Fee Schedule Search Tool to look up pricing amounts, various payment policy indicators, RVUs, and GPCIs, and to search for national payment amounts, a specific Carrier/Medicare Administrative Contractor (MAC) or a specific Carrier/MAC locality.
The rule calls for an across-the-board 26.5 percent reduction in payment rates based on the current sustainable growth rate (SGR) formula. View the effect of the 2013 physician fee schedule final rule on key dermatology codes. This table outlines the 2013 reimbursement rate changes before the SGR cut and with the expected SGR freeze by Congress.
CMS accepted the majority of the American Medical Association/Specialty Society Relative Value Update Committee (RUC) recommendations on almost 30 dermatology codes that were surveyed in 2012. There were some changes to the relative value units (RVUs) for dermatology codes, but the overall effect to dermatology is not expected to be significant.
The final rule contains a number of policy refinements, including moving ahead with implementing the physician value-based payment modifier for groups of physicians with more than 100 eligible professionals. In addition, CMS has added an appeals process to the e-prescribing program and two additional penalty exemptions for physicians participating in the electronic health records incentive program. Read the full text of the final rule here.
Complex repair codes
CMS accepted the majority of the AMA RUC recommendations for complex repair codes, with some exceptions. Values were roughly maintained at current payment levels for most of the codes in the complex repair code family, but the final 2013 fee schedule included a reduction to 13152 by 13 percent, and 13132 by 16 percent — which are mostly due to a cut in physician work relative value units (RVU).
For 13152, the physician work RVU was cut 23.08 percent; the practice expense RVU was cut 4.4 percent. For 13132, the physician work RVU was cut 27.36 percent; the practice expense RVU was cut 7.59 percent. The effect of 2013 final rule will be greater if Congress fails to issue a freeze to the SGR.
View the effect of the 2013 physician fee schedule final rule on complex repair codes.
Reimbursement reduction: 88305 TC
However, other codes that dermatologists may use, such as 88305, did not fare as well and the effect on individual practices will vary. The final 2013 fee schedule included a significant reduction in reimbursement for the technical component (TC) of surgical pathology code 88305. That code’s TC will be cut by 52 percent, although the professional component (PC) will be raised by 2 percent. Overall, the global value of 88305 was reduced by 33 percent.
AADA staff will continue to analyze the final rule for its effect on dermatology and will provide further updates. Additionally, the AADA will submit comments to CMS prior to the Dec. 31 deadline. Read more information about dermatopathology reimbursement in Dermatology World.
Refinements to policy initiatives
In addition, the final rule contains a number of refinements to policy initiatives. CMS will reduce the threshold for reporting the electronic prescribing measure (eRx), add an appeals process and two additional penalty exemptions for participating physicians, and allow group practices of 2 to 24 eligible professionals to participate in the eRx program in 2013. Read more about refinements to policy initiatives within the final fee schedule.
Proposed fee schedule rule for 2013
Throughout the year, the AADA has actively weighed in on this rulemaking process with regard to important provisions affecting physician payments. In July 2012, CMS released its proposed rule for the 2013 Medicare fee schedule. Read the AADA comments on the proposed rule here. Read the AADA comments on the final rule here.