ISASS Policy & Advocacy News – November 2016

CMS Releases Final MACRA/Quality Payment Program Rule
November 28, 2016
Vertebral Columns – Fall & Winter 2016
December 22, 2016
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News and noteworthy information for November 2016:

  • CMS Releases 2017 Final Physician Fee Schedule
  • CMS Releases 2017 Final Hospital Outpatient and ASC Rule
  • CMS Releases Final MACRA/Quality Payment Program Rule

 

CMS Releases 2017 Final Physician Fee Schedule

On November 2, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that updates payment policies, payment rates and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2017. The PFS pays for services furnished by surgeons, physicians, and other practitioners in all sites of service. These services include but are not limited to visits, surgical procedures, diagnostic tests, therapy services, and specified preventive services.

As part of the final rule, CMS assigned final values to the following new surgical spine codes set to take effect January 1, 2017:

Code Descriptor
22853

Insertion of interbody biomechanical device(s) (eg, synthetic cage, mesh) with integral anterior instrumentation for device anchoring (eg, screws, flanges) when performed to intervertebral disc space in conjunction with interbody arthrodesis, each interspace

22854

Insertion of intervertebral biomechanical device(s) (eg, synthetic cage, mesh) with integral anterior instrumentation for device anchoring (eg, screws, flanges) when performed to vertebral corpectomy(ies) (vertebral body resection, partial or complete) defect, in conjunction with interbody arthrodesis, each contiguous defect

22859

Insertion of intervertebral biomechanical device(s) (eg, synthetic cage, mesh, methylmethacrylate) to intervertebral disc space or vertebral body defect without interbody arthrodesis, each contiguous defect

22867

Insertion of interlaminar/interspinous process stabilization/distraction device, without fusion, including image guidance when performed, with open decompression, lumbar; single level

22868

Insertion of interlaminar/interspinous process stabilization/distraction device, without fusion, including image guidance when performed, with open decompression, lumbar; second level

22869

Insertion of interlaminar/interspinous process stabilization/distraction device, without open decompression or fusion, including image guidance when performed, lumbar; single level

22870

Insertion of interlaminar/interspinous process stabilization/distraction device, without open decompression or fusion, including image guidance when performed, lumbar; second level

62380

Endoscopic decompression of spinal cord, nerve root(s), including laminotomy, partial facetectomy, foraminotomy, discectomy and/or excision of herniated intervertebral disc; 1 interspace, lumbar

Additionally, after receiving substantial pushback from the physician community and medical societies including ISASS, CMS finalized a data collection strategy for surgical codes with 10- and 90-day global periods that significantly reduces the burden on surgeons and their practices compared to the proposed rule.

A full summary of the final rule is available here. A spreadsheet comparing spine code values and reimbursements from 2016 to 2017 is available here. The final rule goes into effect on January 1, 2017.

 

CMS Releases 2017 Final Hospital Outpatient and ASC Rule

On November 1, 2016, the Centers for Medicare & Medicaid Services (CMS) released the 2017 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System policy changes, quality provisions, and payment rates final rule. Please note that physician payment is made under the Physician Fee Schedule; hospitals are paid for outpatient services under the OPPS and ASCs are paid under the ASC payment system, both detailed in this rulemaking.

For 2017, CMS is updating OPPS rates by 1.65 percent.  After considering all other policy changes proposed under the OPPS, including estimated spending for pass-through payments, CMS estimates a 1.7 percent payment increase for hospitals paid under the OPPS in 2017. ASC payments are annually updated by the percentage increase in the Consumer Price Index for all urban consumers (CPI-U). The Medicare statute specifies a multi-factor productivity (MFP) adjustment to the ASC annual update. For 2017, the CPI-U update is projected to be 2.2 percent. The MFP adjustment is projected to be 0.3 percent, resulting in an MFP-adjusted CPI-U update factor of 1.9 percent.

As part of the final rule, CMS is removing the following surgical spine codes from the inpatient-only list:

  • CPT Code 22585 – Arthrodesis, anterior interbody technique, including minimal discectomy to prepare interspace (other than for decompression); each additional interspace (List separately in addition to code for primary procedure))
  • CPT Code 22840 – Posterior non-segmental instrumentation (eg, Harrington rod technique, pedicle fixation across 1 interspace, atlantoaxial transarticular screw fixation, sublaminar wiring at C1, facet screw fixation) (List separately in addition to code for primary procedure));
  • CPT Code 22842 – Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and sublaminar wires); 3 to 6 vertebral segments (List separately in addition to code for primary procedure));
  • CPT Code 22845 – Anterior instrumentation; 2 to 3 vertebral segments (List separately in addition to code for primary procedure));
  • CPT Code 22858 – Total disc arthroplasty (artificial disc), anterior approach, including discectomy with end plate preparation (includes osteophytectomy for nerve root or spinal cord decompression and microdissection); second level, cervical (List separately in addition to code for primary procedure))

As part of the final rule, CMS is adding the following surgical spine codes to the list of ASC covered surgical procedures:

  • CPT Code 20936 – Autograft for spine surgery only (includes harvesting the graft); local (eg, ribs, spinous process, or laminar fragments) obtained from the same incision (List separately in addition to code for primary procedure));
  • CPT Code 20937 – Autograft for spine surgery only (includes harvesting the graft); morselized (through separate skin or fascial incision) (List separately in addition to code for primary procedure));
  • CPT Code 20938 – Autograft for spine surgery only (includes harvesting the graft); structural, biocortical or tricortical (through separate skin fascial incision));
  • CPT Code 22552 – Arthrodesis, anterior interbody, including disc space preparation, discectomy, osteophytectomy and decompression of spinal cord and/or nerve roots; cervical C2, each additional interspace (List separately in addition to code for separate procedure) );
  • CPT Code 22585 – Arthrodesis, anterior interbody technique, including minimal discectomy to prepare interspace (other than for decompression); each additional interspace (List separately in addition to code for primary procedure));
  • CPT Code 22840 – Posterior non-segmental instrumentation (eg, Harrington rod technique, pedicle fixation across 1 interspace, atlantoaxial transarticular screw fixation, sublaminar wiring at C1, facet screw fixation) (List separately in addition to code for primary procedure));
  • CPT Code 22842 – Posterior segmental instrumentation (eg, pedicle fixation, dual rods with multiple hooks and sublaminar wires); 3 to 6 vertebral segments (List separately in addition to code for primary procedure));
  • CPT Code 22845 – Anterior instrumentation; 2 to 3 vertebral segments (List separately in addition to code for primary procedure))
  • CPT Code 22853  – Insertion of interbody biomechanical device(s) (eg, synthetic cage, mesh) with integral anterior instrumentation for device anchoring (eg, screws, flanges), when performed, to intervertebral disc space in conjunction with interbody arthrodesis, each interspace (List separately in addition to code for primary procedure));
  • CPT Code 22854 – Insertion of intervertebral biomechanical device(s) (eg, synthetic cage, mesh) with integral anterior instrumentation for device anchoring (eg, screws, flanges), when performed, to vertebral corpectomy(ies) (vertebral body resection, partial or complete) defect, in conjunction with interbody arthrodesis, each contiguous defect (List separately in addition to code for primary procedure)); and
  • CPT Code 22859 – Insertion of intervertebral biomechanical device(s) (eg, synthetic cage, mesh, methylmethacrylate) to intervertebral disc space or vertebral body defect without interbody arthrodesis, each contiguous defect (List separately in addition to code for primary procedure))

A full summary of the final rule is available here. A spreadsheet detailing spine procedure reimbursements to hospitals for outpatient procedures and spine procedure reimbursements to ASCs in 2017 is available here. Please note, the spreadsheet has three tabs: 1. spine procedure reimbursements to ASCs, 2. spine procedure reimbursements to hospitals for outpatient procedures; 3. Hospital Outpatient Ambulatory Payment Classifications (APCs).

CMS is accepting comments on the final rule through December 31, 2016. Comments should be submitted here using the “Comment Now!” button on the right side of the page. The final rule goes into effect January 1, 2017.

 

CMS Releases Final MACRA/Quality Payment Program Rule

On October 14, the Centers for Medicare and Medicaid Services (CMS) issued the final rule implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA was bipartisan legislation signed into law in April 2015 to permanently repeal the Sustainable Growth Rate (SGR), streamline physician quality reporting programs, and provide incentive payments for physician participation in alternative payment models. MACRA sunsets the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program and establishes an umbrella Quality Payment Program with two new pathways for payment: 1. Merit-Based Incentive Payment System (MIPS) and 2. Advanced Alternative Payment Models (Advanced APMs). The new Quality Payment Program dramatically changes the way Medicare reimburses more than 600,000 clinicians across the country.

CMS made significant changes to the Quality Payment Program in the final rule after receiving feedback from the physician community and medical societies, including ISASS, during the public comment period on the proposed rule.

A full summary of the final rule is available here. CMS is accepting comments on the final rule through December 19, 2016. Comments should be submitted here using the “Comment Now!” button on the right side of the page. The final rule goes into effect January 1, 2017.

For more information on how to prepare your practice for MACRA, please join one of the educational seminars hosted by the American Medical Association (AMA) on December 1, December 6 and December 10:

 

Thursday, December 1 – 6:30 p.m. – 9 p.m. Eastern Time

Atlanta Regional Seminar (streaming and webinar)

Cobb Galleria Center

Atlanta, Georgia

Registration: https://www.eventbrite.com/e/macra-regional-seminar-atlanta-tickets-28840143646

 

Tuesday, December 6, 8:00 p.m. – 9:30 p.m. Eastern Time

Physician/staff Webinar

Registration: https://cc.readytalk.com/r/j8d0v8kh1qr3&eom

 

Saturday, December 10, 9:00 a.m. – 11:30 a.m. Pacific Time

San Francisco Regional Seminar (streaming and webinar)

Marriot Marquis

San Francisco, CA

Registration: https://www.eventbrite.com/e/macra-regional-seminar-san-francisco-tickets-28863673023