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2018 Fee Schedule and Hospital Outpatient Rules Released; CMS Finalizes Delay of AUC Program to 2020

The Centers for Medicare and Medicaid Services (CMS) issued its CY 2018 final payment policies and payment rates for services furnished under the Medicare Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (OPPS). Payment rates and policies set forth in these rules are effective Jan. 1, 2018.
Medicare Physician Fee Schedule
The update to payments under the PFS based on the proposed CY 2018 rates will be +0.41 percent. This update reflects the statutory +0.50 percent update under MACRA, reduced by 0.09 percent, due to the misvalued code target recapture amount.
 
After applying these adjustments, the budget neutrality adjustment and accounting for changes in RVUs — all required by law—the final 2018 PFS conversion factor is 35.99, an increase to the 2017 PFS conversation factor of 35.89.
  
Medicare Appropriate Use Criteria Program
CMS finalized delaying the effective date of the Appropriate Use Criteria (AUC) Program to Jan. 1, 2020. CMS had proposed delaying the program until Jan. 1, 2019. ASNC has led an advocacy effort composed of multiple physician stakeholder groups calling for indefinite delay of the AUC Program while its value and necessity were evaluated in the context of the Quality Payment Program (QPP). By further delaying the program in the Final Rule, CMS is acknowledging that it agrees with commenters that the goals of the QPP are consistent with those of the AUC program.
 
CMS also has finalized a voluntary period (July 2018-December 2019) during which clinicians may begin documenting limited consultation information on Medicare claims forms.  During the period of voluntary reporting, there will be no requirement that the ordering professional consult AUC or the furnishing professional report information related to the consultation. An AUC Program operations and testing period will begin Jan. 1, 2020. During this testing period, ordering professionals must consult specified applicable AUC through qualified clinical decision support mechanisms (CDSMs) and furnishing professionals must report the AUC consultation information on the Medicare claim. However, CMS will continue to pay claims regardless of whether they correctly include information related to the consultation of AUC.
 
CMS also has finalized allowing clinicians to earn credit under the Merit-based Incentive Payment System (MIPS) program by consulting AUC using a CDSM as an improvement activity.
 
Hospital Outpatient Prospective Payment System
CMS also finalized an update of Hospital Outpatient Prospective Payment System (OPPS) rates by 1.35 percent for 2018. The change is based on the projected hospital market basket increase of 2.7 percent minus both a 0.6 percentage point adjustment for multi-factor productivity and a 0.75 percentage point adjustment required by law. After considering all other policy changes proposed under the OPPS, including estimated spending for pass-through payments, CMS estimates an overall impact of 1.4 percent payment increase for hospitals paid under the OPPS in CY 2018.

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