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CMS Releases Proposed Rule for the CY2015 Physician Fee Schedule

July 11, 2014—The Centers for Medicare and Medicaid Services (CMS) July 3 released a proposed rule for changes to the calendar year (CY) 2015 Physician Fee Schedule. Key proposals include a new care coordination code, final implementation of the Physician Value-based Modifier (VBM), changes to global payments, modifications for the quality reporting for the Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO), and changes to the Physician Quality Reporting System (PQRS), the Medicare EHR Incentive Program, Physician Compare Website, and the Open Payments Program.

As part of its efforts to increase support for primary care services, CMS proposes to create a separate payment to reimburse providers for non-face-to-face services provided to patients with two or more chronic care conditions. Known as Chronic Care Management (CCM) and originally introduced in last year’s PFS Final Rule, the new code can be billed no more than once per month per qualifying beneficiary. A payment rate of $41.92 has been proposed by CMS. 

CMS also outlines its proposal to apply the VBM, the physician pay-for-performance, to all physicians in CY 2017, as required by the Affordable Care Act, based on performance in 2015.  CMS proposes to double the maximum downward adjustment from negative 2.0 percent to negative 4.0 percent of Medicare paid charges. CMS also proposes to expand the VBM to ACOs and to non-physician clinicians that are covered under PQRS.

In CY 2015, PQRS transitions from payment incentives for reporting to payment penalties for not reporting. CMS also includes proposals for the 2015 performance period which impacts the 2017 payment period. A major proposals is requiring “cross-cutting” measures for professionals who have face-to-face visits and who report via certain mechanisms.

In terms of the MSSP, CMS proposes to recognize ACOs that improve their quality performance on a year-to-year basis by adding a quality improvement measure that will add bonus points to each of the four quality domains used to determine performance. The number of quality measures will also increase under the proposal with new measures being added to focus on avoidable admissions for patients with chronic conditions, heart failure and diabetes; depression remission; all cause readmissions to a skilled nursing facility; and stewardship of patient resources. 

CMS also is seeking comments on future quality measures to consider for the program; gaps in measures; measures considered for retirement; aligning MSSP with the value-based modifier (VBM); and others.

In regards to the Open Payments Program, also known as the “Sunshine Act,” the proposal with the biggest impact for academic medical center is CMS’s plan to eliminate the specific exemption for payments to speakers at certain accredited continuing medical education events.

Finally, CMS estimates that the PFS update, which is calculated using the sustainable growth rate (SGR) formula, for services provided starting April 2015 would be negative 20.9 percent unless Congressional action is taken to avert the scheduled reduction. Congress has consistently voted to overturn the SGR payment cuts.

CMS will publish the proposed rule in the July 11 Federal Register. Comments are due Sept. 2, 2014. The AAMC will be submitting comments.

Additional opportunities for AAMC members to learn about these proposals will be available in the coming weeks.


Evan Collins, MHA
Specialist, Clinical Operations and Policy
Telephone: 202-828-0552

Mary Patton Wheatley, M.S.
Director, Health Care Affairs
Telephone: 202-862-6297

Heather Pierce, JD, MPH
Sr. Director, Science Policy & Regulatory Counsel
Telephone: 202-478-9926

(for open payments)


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806