On November 23, 2018, the Centers for Medicare & Medicaid Services (CMS) published the final rule changes for the 2019 calendar year. How will they affect nuclear medicine and your practice in particular? After all the noise in 2018, the changes were minimal. It seems that 2019 will be following suit:
Hospital procedure rates remain nearly static
On the hospital side, CMS has continued to evaluate and adjust the cost of procedures that are either under- or overvalued. The majority of nuclear medicine procedures will see a minimal increase of between 0.5% and 2.2%. The slightly more significant but far from dramatic adjustments will be made to codes for administering radiopharmaceutical therapies, which will see a decrease of 3.3%.
One notable change was made in direct response to the administrative burden that meaningful use measures and quality reporting placed on providers. In 2019, not only will no new meaningful use and quality measures be implemented, but CMS will look to reduce the current policy. The reduction is aimed at allowing providers the ability to focus on the measures that are most meaningful and impactful on their patient care.
Site neutrality payment cuts
More interesting, however, was CMS’ decision to neutralize payment variances between the Hospital Outpatient Prospective Payment System and the Ambulatory Surgical Center Payment System. By implementing a Physician Fee Schedule (PFS)-equivalent payment rate for an off-campus provider-based department (PBD) clinic visit that is paid under the OPPS, patients will benefit from high-quality care and lower copayments.
In order to further evaluate the unnecessary increases they’ve seen in services rendered at PBDs, however, CMS will establish a moratorium on the addition of any new off-campus PBDs. Existing locations will continue with business as usual, and CMS will monitor the total amount of payments made under the current arrangements. Any follow up to this issue will likely be addressed in the 2020 or 2021 ruling.
Physician fee schedule sees positive change
Overall, current projections are seeing a negligible increase, barely 1%, in nuclear medicine. Procedure rates are slated to remain largely the same, based on the national unadjusted average.
An additional year for AUC preparation
One of the biggest reliefs in the final ruling has to do with the effective date for adherence to authorized use criteria (AUC), which has been postponed numerous times and last slated to take effect on July 1, 2019. Many of the medical societies voiced their concern about the preparedness of providers and their ability to implement a new system by mid-year. CMS responded by designating 2019 as an education year with a revised effective date of January 2020.