CMS’s 2017 Physician Fee Schedule (PFS) proposed rule offers a lot for organizations interested in transformation to celebrate. In addition to making a number of tweaks to the Shared Savings Program that demonstrate CMS leadership are listening to provider feedback, the proposed rule removes barriers for rural health care organizations to offer more preventative and consultative services.
Most importantly, CMS proposes to remove the requirement for direct supervision in rural health clinics and federally qualified health centers when providing comprehensive care management (CCM) services. When CMS first finalized CCM as a billable service, the agency determined that for rural clinics and federally qualified health centers the primary practitioner must directly supervise all aspects of the care. In the proposed rule CMS would allow such facilities to use general supervision for services incident to CCM, just as currently allowed in a standard physician office.
CMS also simplified the conditions for practitioners operating in all settings to provide CCM services, removing cumbersome requirements for a comprehensive pre-visit as well as written agreement to receive services and share health information. They also propose important new payments for care coordination and behavioral health integration. Caravan Health will assist you in implementing these new codes once approved.
Additionally, in a significant sign that CMS is thinking about our rural members, two new telehealth codes are proposed that will allow clinicians to offer advance care planning remotely.
CMS also proposes a new program focused squarely on prevention in high risk populations. The Medicare Diabetes Prevention Program would begin January 1, 2018 and offer an opportunity for providers to partner with local community organizations or even host prevention programs themselves. CMS is seeking comments on all aspects of the new program, and we expect to see at least one more round of additional rule-making on this before the program rolls out.
Finally, CMS is proposing a few new quality measures and sun-setting others. They also propose changes to the audit process and are considering beneficiary self-assignment.
Click here to read Caravan Health’s full analysis of the proposed rule.
We will have a webinar to review the proposed rule on Tuesday, Aug. 23 at 9am PT/11am CT/12pm ET. To join, log in to www.readytalk.com, participant code 5004777. If you are unable to access the web-audio function, dial 303.248.0285.
Comments on the proposed rule will be accepted by CMS until 5pm EST September 6, 2016. A final rule is expected no later than November 1, 2016.
LeeAnn Hastings Director of Policy & Compliance Caravan Health