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Washington Highlights

CMS Releases CY 2015 Physician Fee Schedule Final Rule

November 7, 2014—The Centers for Medicare and Medicare Services (CMS) Oct. 31 released the calendar year (CY) 2015 Physician Fee Schedule (PFS) final rule, finalizing much of what was outlined in the proposed rule, including doubling the amount at risk under the Value Based Payment Modifier (VM) for most physician groups starting CY 2017. The agency also finalized a plan to transition to 0-day global surgery codes starting in 2017, a delay in identifying services occurring on off-campus locations, modifications for the quality reporting requirements for the Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs), and changes to the Open Payments program.

CMS also confirmed that physician payments will decrease 21.2 percent on April 1 unless Congress intervenes. The physician update formula is set in law and Congress has consistently intervened to prevent the cuts from occurring.

A summary of the key changes finalized in the rule include:

  • Starting CY 2017, eligible professionals (EPs) in groups of 10 or more will face 4 percent of payments at risk under the VM, an increase from 2 percent in CY 2016 (performance will be measured on CY 2015 data). These groups will now be at risk for a total of 9 percent through the penalties associated with the VM, electronic health record (EHR) Incentive program, and the Physician Quality Reporting System (PQRS). The Agency did not finalize this change for EPs in groups less than 10. These groups will face a maximum downward adjustment of 2 percent of payments under the VM in CY 2017, for a total of 7 percent at risk for all of the physician quality programs.   

  • Large group practices (with at least 100 eligible professionals) will be required to report patient experience measures if they participate in PQRS group reporting. 

  • CMS will transition to 0-day global surgery codes. 10-day global codes will transition starting in 2017 and 90-day global codes will transition in 2018.

  • The ACO quality scoring methodology was adjusted to provide extra credit for performance improvement.

  • A one year delay in mandatory identification of services for providers who work in off-campus hospital outpatient departments. Voluntary reporting will start Jan. 1, 2015. Mandatory reporting will start Jan. 1, 2016

  • Addition of a new chronic care management (CCM) code, which allows a monthly payment rate of $40.39 per qualified patient.

The AAMC submitted comments  in response to the CY 2015 PFS proposed rule in September 2014 [see Washington Highlights, Sept. 5].

Regarding the Open Payments, or Sunshine Act, program, CMS finalized all four proposed changes, including eliminating the specific reporting exclusion for payments to speakers at accredited CME activities. Although AAMC and many other organizations have urged CMS to retain the exclusion to provide clarity for manufacturers about reporting obligations related to supporting CME activities, by eliminating this provision CMS is not requiring that all payments to speakers at accredited CME activities be reported by companies as indirect payments [see Washington Highlights, Sept. 5]

Instead, CMS clarifies in the Federal Register commentary that the specific exclusion was never necessary because these type of payments do not meet the criteria for reportable indirect payments.


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

Scott Wetzel, M.P.P.
Lead, Quality Reporting
Telephone: 202-828-0495

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


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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