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CMS Publishes CY 2019 Physician Fee Schedule/QPP Final Rule

November 8, 2018

The Centers for Medicare & Medicaid Services (CMS) issued a final rule recently that includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Fee Schedule starting on January 1, 2019.

Some highlights that impact therapists include:
  • Discontinuance of Functional Status Reporting Requirements for Outpatient Therapy: Because of the repeal of therapy caps in 2018, CMS has stated that it no longer needs to collect non-payable G code data on services furnished after January 1, 2019.
  • Outpatient PT and OT Services Furnished by PTAs: Starting in 2020, therapy provided by a PTA or OTA will be paid at 85% of the Medicare Part B Fee Schedule. In addition, there are two new modifiers that will be used when services are performed by a PTA or OTA.
  • PTA Modifier CQ: Outpatient physical therapy services furnished in whole or in part by a physical therapist assistant.
  • OTA Modifier CO: Outpatient occupational therapy services furnished in whole or in part by an occupational therapy assistant.

CMS is therefore not modifying the existing GP, GO, and GN therapy modifier.

  • KX Modifier Amount: Must be attached after $2,040 to show Medical Necessity of treatment.
  • Conversion Factor: Under the proposed rule, CMS estimates that the CY 2019 conversion factor would be $36.05, a slight increase of the CY2018 conversion factor of $35.99.

CMS states that facility-based outpatient therapy and SNF claims will not be eligible for MIPS because the claims do not contain the rendering NPI.

The proposed changes to the QPP aim to reduce clinician burden, focus on outcomes, and promote interoperability of electronic health records (EHRs).

The proposed changes seek to accomplish this by:

  • Reducing MIPS process-based quality measures that clinicians have said are low-value or low-priority, in order to focus on meaningful measures that have a greater impact on health outcomes.
  • Overhauling the MIPS “Promoting Interoperability” performance category to support greater EHR interoperability and patient access to their health information, as well as align this performance category for clinicians with the proposed new Promoting Interoperability Program (PIP) for hospitals.
  • CMS also proposes waivers of MIPS requirements as part of testing a demonstration called the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) demonstration. The MAQI demonstration would test waiving MIPS reporting and payment adjustments for clinicians who participate sufficiently.

Want to dig deeper into the updates? Check out the CMS Fact Sheet or contact us today to speak with one of our CMS experts.

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