In June and July, the Centers for Medicare and Medicaid Services (CMS) released proposed rules outlining policies and payment rates for Medicare’s Quality Payment Program (QPP/MACRA), Physician Fee Schedule (MPFS), and Hospital Outpatient Prospective Payment System (HOPPS) for services provided on or after January 1, 2018.  Summaries of the proposed rules and charts showing the 2018 proposed payment rates for the major services provided by epilepsy centers can be found below.

Highlights of the Proposed Rules

Medicare Quality Payment Program/Proposed Changes to MACRA for 2018 – Beginning last year, CMS now releases a separate proposed rule on the Quality Payment Program (QPP) authorized under the MACRA legislation. Eligible physicians can participate in one of two payment tracks: the Merit-Based Incentive Payment System (MIPPS) or the Advanced Alternative Payment Models (APMs).  CMS is proposing a number of changes for 2018 for these programs with the intent of reducing burdens on reporting clinicians while maintaining high quality care.  The rule allows for additional clinicians to be exempted from the MIPS program by increasing the threshold for participation to annual Part B charges of $90,000 or 200 Medicare patients and small practices will receive additional points to assure that most small practices are not penalized.  The rule also proposes to delay the cost component of MIPS for an additional year, allows for solo practitioners to form “virtual” groups for reporting purposes, and allows hospital-based physicians to report facility-based measures.  A summary of the rule can be found here.

Medicare Physician Fee Schedule for 2018 – CMS is proposing a conversion factor (CF) of $35.99 for 2018, a slight increase over the 2017 CF.  Payment rates for neurology and evaluation and management (E/M) services will remain pretty stable in 2018.  The rule calls for a reduction in payment for services provided by “off-campus provider-based hospital departments,” an extension of a policy adopted by CMS last year.  In 2018, payment rates for non-excepted services provided in provider-based departments will equal to 25% of the HOPPS payment rate rather than the current payment rate, which was set at 50% of HOPPS.  CMS is seeking comments on whether to remove the documentation requirements related to history and physical exams for reporting E/M services and suggests that medical decision making and time be used to determine the level of E/M codes to report.  Other changes proposed in the rule includes an expansion of the covered telehealth services and an update in the malpractice relative values to reflect more current data.  For more information, please review, a summary of the MPFS rule and charts showing the proposed 2018 payment rates.

Medicare Hospital Outpatient Prospective Payment System (HOPPS) for 2018 – The rule proposes a 1.75% update in hospital outpatient payment rates in 2018.  The HOPPS payments cover facility resources including equipment, supplies, and hospital staff, but do not include services of physicians or non-physician practitioners paid separately under the Medicare Physician Fee Schedule. Services under OPPS, which are clinically similar and require similar resources are classified into payment groups called Ambulatory Payment Classifications (APCs) and a payment rate is established for each APC.  The APCs for epilepsy services are mostly increasing in 2018 by 1.5% to 4%.  A chart showing the HOPPS payment rates for services provided by epilepsy centers can be found here.