On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that includes proposals to update payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2019.

Our CFO, Rylan Smith, shares his thoughts on this proposal, which could have a significant impact on our physicians:

I share in the healthcare industry’s optimism that CMS is going to move payment models to focus more on patient quality care. Our physicians have experienced significant confusion regarding requirements for MIPS, so any new ways to streamline reporting would be welcomed.

On the other hand, I also share in the healthcare industry’s concerns regarding reimbursement. When you go to a blended rate, those who tend to suffer the most are the providers offering a higher acuity of care. In wound care, because we deal with chronic patients, we typically see that higher acuity. There’s a good chance that this blended rate will result in a reduction of reimbursements for our physicians.

Another challenge we’ve faced is on the facility provider side. Just because Medicare has gone to a blended rate, doesn’t mean all other insurance payers will match that methodology. The facility E&M code for Medicare has been a blended rate for a couple of years now, but we still have to track different levels of service because not all payers have made that switch. This has led to documentation confusion among hospital providers as well as a loss of revenue opportunities.

At this point, the new changes are in the proposal phase. The original methodology of determining the level of care was released in 1995, so it’s about time we make meaningful change. We encourage all providers to voice their concerns now.