If you want to participate in the comment process, you need to start somewhere. The best place is here, with a brief description of the key elements in the proposal.
Telehealth Services: These services would be expanded to include areas designated as health professional shortage areas (HPSAs)
located in rural census tracts of urban areas as determined by the
Office of Rural Health Policy. Additionally, transitional care
management services would be considered eligible telehealth services.
Revisions To The Practice Expense Geographic Adjustment:
PFS rates are calculated based on numerous factors as required by the
Medicare law. The main goal is to adjust payments according to
geographic differences in practice costs. To accomplish this, CMS
assigns separate geographic practice cost indices (GPCIs)
to the work, practice expenses (PE), and malpractice cost components of
each of more than 7,000 physicians’ services. The proposed changes to
the GPCIs would be phased in over 2014-2015 and are:- New GPCIs using updated data as required by law every 3 years.
- Changes to the weights assigned to each GPCI (work, PE and malpractice) consistent with the recommendations of the Medicare Economic Index (MEI) Technical Advisor Panel (see below) that increases the weight of work and reduces the weight of practice expense.
- The proposed GPCIs reflect the elimination of the work “floor” and as a result 51 localities will have a work GPCI below 1.
Medicare Economic Index: MEI,
the price index used to update the PFS for inflation, and sustainable
growth rate are used in when calculating the total payment amounts in
the PFS. The proposal reflects 2012 recommendations by a Technical
Advisory Panel CMS that will revise the calculation of the MEI as well
as changes in the RVU and GPCI weights assigned to work and practice
expense to align with the MEI. 
Miss-valued Codes:
CMS as part of the ACA, has identified miss-valued codes requiring
adjustment to payment rates. There are more than 200 codes with
proposed rate changes. These codes currently reimburse higher for
services performed in an office versus the fee paid in a hospital
outpatient setting or ASC. The proposed rates would reflect a PFS
office place of service reimbursement that is equal to the sum of the
reimbursement to the facility and practitioner when service are rendered
in an outpatient hospital or ACS place of service. There have been
additional miss-valued codes identified by Medicare Contractors based on
claim review that have proposed reimbursement changes.
Application of Therapy Caps to Critical Access Hospitals: They
are proposing outpatient therapy services furnished in CAHs are added
to the therapy cap limitations. This would apply two per beneficiary of
the following outpatient therapy services:- physical therapy and speech-language pathology services
- occupational therapy services.
Future change for 2015 included in this proposal:
Primary Care and Complex Chronic Care Management:
The proposal would provide for an additional, separate payment for a
practitioner that provides non-face-to-face complex chronic care
management services for Medicare beneficiaries who have multiple,
significant chronic conditions (two or more). This is how it would
work:- Coverage is based on the physician development and revision of a plan of care, communication with other treating health professionals, and medication management
- Beneficiaries would be required to have an Annual Wellness Visit (or an Initial Preventive Physical Examination (IPPE), if applicable)
- Would apply to a single practitioner that agrees to furnish these services and that obtains the beneficiary’s consent to receiving these services over a one-year period.
- Medicare would make the separate payment through two G-codes for establishing of a plan of care and furnishing care management over 90-day periods.
To access the CMS Fact Sheet click here.
To read the entire proposed rule click here.
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