2008 Final Rule for the Medicare Physician Fee Schedule (MPFS)
The 2008 final MPFS rule was released on November 1, 2007 on
the CMS website. The final rule includes a negative 10.1 percent
update in reimbursement to physicians as a result of the
sustainable growth rate (SGR) formula. The rule will be published
in the Federal Register on November 27, 2007. It is effective
January 1, 2008.
Key highlights of the final 2008 MPFS rule include:
Payment for Contrast Agents and
Radiopharmaceuticals
Payment will continue to be made for contrast agents at ASP +
6% and for radiopharmaceuticals at either 95% of Average
Wholesale Price or invoice (varies by local carrier).
Multiple Diagnostic Imaging Procedure Payment
Reduction
The rule continues a 25% reduction to the technical component
(-TC) of second and subsequent procedures done on contiguous
body parts in the same imaging session within the 11 imaging
families below. The 25% reduction will be taken prior to any
other reductions resulting from decreases mandated by the
Deficit Reduction Act (DRA) of 2005.
Family 1 Ultrasound (Chest/Abdomen/Pelvis - Non-Obstetrical)
Family 2 CT and CTA (Chest/Thorax/Abd/Pelvis)
Family 3 CT and CTA (Head/Brain/Orbit/Maxillofacial/Neck)
Family 4 MRI and MRA (Chest/Abd/Pelvis)
Family 5 MRI and MRA (Head/Brain/Neck)
Family 6 MRI and MRA (Spine)
Family 7 CT (Spine)
Family 8 MRI and MRA (Lower Extremities)
Family 9 CT and CTA (Lower Extremities)
Family 10 MR and MRI (Upper Extremities & Joints)
Family 11 CT and CTA (Upper Extremities)
DRA Limits on the Technical Component
The DRA requires that payment for certain imaging services
performed in physician offices and freestanding imaging centers
be limited to the hospital outpatient department amount
for the technical component of those services. CMS then applies
the MPFS geographic adjustment to the capped payment
amount. If the multiple procedure adjustment discussed above
also applies, CMS makes that adjustment first and then applies
the DRA cap.
CMS clarified in the rule that the DRA cap will not be applied to
procedures that are packaged under the HOPPS methodology.
Practice Expense Methodology
The rule reflects changes for the second year (2008) of a fouryear
transition in methodology for the practice expense relative
value units (RVUs). For 2007, CMS adopted a “bottom-up”
methodology for calculating direct expenses that they believe is
more transparent than the “top down” approach. The new
methodology is expected to stabilize the practice expense portion
of payment so that changes in the RVUs don’t produce significant
swings in payment for a given procedure. This would
allow for better prediction of the impact of the changes as well
as improve the accuracy of the practice expense payments.
Independent Diagnostic Testing Facility
Standards
CMS adopted the standards previously proposed with some
modifications. The standards addressed in the final rule include
comprehensive liability requirements, reporting of enrollment
information, clarification of documentation needed when a
complaint is received, responsibilities for supervising physicians,
commingling of office space, initial enrollment date, and
number of sites allowed per supervising physician.
Physician Quality Reporting Initiative
The final rule addresses this voluntary program initiated
July 1, 2007 in which physicians report various quality measures
in order to receive a bonus of 1.5%, subject to meeting certain
requirements. The list currently includes 74 measures of quality
that are reported in a claims-based submission format. CMS is
evaluating alternative formats for the quality data.
For more information about the MPFS rule, please visit: http://www.cms.hhs.gov/PhysicianFeeSched/PFSFRN/list.asp?listpage=2 |