Q: Why does my 2009 Medicare fee schedule look so similar to my 2008 Medicare fee schedule?
A: Despite the Medicare Improvements for Patients and Providers Act of 2008 (H.R. 6331) providing for a 1.1-percent increase to the physician fee schedule for 2009, actual changes in the MPFS were negligible. The 2009 conversion factor of $36.0666 is substantially lower than the 2008 conversion factor of $38.0870, but the budget neutrality adjuster applied to the work value of each service was applied to the conversion factor instead in 2009. The net result is a 2009 fee schedule that looks very similar to the 2008 fee schedule.
Q: Did MIPPA offer a permanent fix to fee schedule issues?
A: No. The flawed sustainable growth rate formula continues as a big concern. Without a permanent fix, projections for 2010 Medicare reimbursement rates are a dire 20-percent reduction. We understand that the incoming administration and legislature place a high priority on health-care reform, and fixing SGR figures to be part of that change.
Q: What reimbursement changes occurred for ASCs?
A: This year is the second year of transition for Ambulatory Surgery Center Medicare payment reform. The 2009 facility reimbursement rates are a 50/50 blend of calendar year 2007 ASC rates and revised ASC payment rates. The Medicare Modernization Act froze the ASC payment rates through 2009. In 2010, the ASC conversion factor updates by the Consumer Price Index for Urban Consumers. For 2009, similar to the physician fee schedule, the overall effect of change from 2008 is insignificant.
Hospital Outpatient Department rates, on the other hand, increased approximately 3 percent for 2009.
Q: What new CPT codes appeared in the 2009 CPT manual?
A: Coding changes include:
• 65756 – Keratoplasty (corneal transplant); endothelial.
• +65757 – Backbench preparation of corneal endothelial allograft prior to transplantation (list separately in addition to primary procedure).
This much-anticipated addition to CPT puts to rest how best to describe the DSEK corneal procedure.
One new Category III code went into effect on January 1, 2009 but will not appear in the published CPT handbook until 2010: 0198T – Measurement of ocular blood flow by repetitive intraocular pressure sampling, with interpretation and report. Reimbursement for Category III codes remains at the carrier's discretion.
Q: Are there any new HCPCS codes in 2009?
A: Yes. Preservative-free triamcinolone acetonide received a unique HCPCS code effective January 1, 2009, J3300: triamcinolone A inj PRS-free. No separate reimbursement exists in a facility (ASC or HOPD) for the drug.
Q: Will we have to prepare for the implementation of ICD-10 in 2009?
A: No. A proposal exists to implement ICD-10 by 2011. There was opposition to this deadline and concerns about the undue cost and burden. Current CMS reports do not contain a definitive date change, but we anticipate a much later date for implementation.
Q: Which ophthalmic services are drawing OIG scrutiny in 2009?
A: The annual publication of the Office of the Inspector General work plan identifies a series of items applicable to ophthalmology. Returning issues include:
• E/M services during global surgery periods;
• "Incident to" services;
• Reassignment of benefits;
• Adherence to assignment rules; and
• Place of service errors.
New issues for scrutiny include:
• Payments for unlisted codes; and
• Medicare billings with modifier -GY.
Q: Will we need to be concerned about the Recovery Audit Contractor Program?
A: Possibly. The three-year demonstration project of the Recovery Audit Contractor program proved very successful to the Center for Medicare & Medicaid Services, with a reported finding of $900M in overpayments. The Tax Relief and Health Care Act of 2006 made the program permanent with plans to expand to all 50 states during 2009. The RAC program and other medical review programs suggest increased investigations.
Q: Are there any additional Part B costs to Medicare beneficiaries in 2009?
A: No. This is good news for the Medicare beneficiary. The Medicare Part B deductible and Part B premiums remained unchanged for 2009. The Part B deductible stayed at $135.
Q: Will the Physician Quality Reporting Initiative continue in 2009?
A: Yes, though several program changes will occur this year. They are:
• Bonuses will increase from 1.5 percent to 2 percent of total annual Medicare allowed dollars.
• The five ophthalmic measures applicable in 2008 remain in 2009.
•Three new ophthalmic measures were added.
1. Comprehensive Preoperative Assessment for Cataract Surgery with IOL.
2. AMD: Counseling on Antioxidant Supplement.
3. Reduction of IOP by 15 percent or Documentation of a Plan of Care.
In order to receive the bonus, providers must successfully report at least 80 percent for each of three quality measures. Participation in PQRI remains voluntary.
Q: Will any effort be made to respond to the issues raised with the 2007 PQRI reports and subsequent bonus payments?
A: Yes. In a December 3, 2008 report, Physician Quality Reporting Initiative 2007 Reporting Experience, CMS provides an analysis of the 2007 PQRI program. The report concedes that unanticipated issues may have affected the success of providers in meeting the program requirements to secure the bonus. It further states that plans exist to apply modified algorithms for 2008 claims, use these same algorithms to the 2007 claims, and rerun the analysis for 2007. This could result in additional bonus payments in the fall of 2009. You can obtain a copy of the report at cms. hhs.gov/ PQRI, in the downloads section.
Q: Is there a second bonus program available to physicians in 2009?
A: Yes. Section 132 of the MIPPA legislation provides for a 2-percent bonus payment to eligible professionals who successfully prescribe (as defined by the statute) their patients' medications electronically beginning in 2009. This is known as e-prescribing.
Like PQRI, the program is not mandatory but the bonus in this one decreases in future years. Beginning in 2012 unsuccessful reporters will be penalized and see Medicare fee schedule reductions of: -1.0 percent for 2012; -1.5 percent for 2013; and -2.0 percent for 2014 and subsequent years.
Q: If I add a new provider in 2009, are there any new enrollment issues?
A: Yes. Practices will no longer be able to file claims retroactively to the start date of the new provider. In 2009 and beyond, practices will only be able to bill for 30 days prior to the later of: the date of filing a clean (processable) Medicare provider application; or the date the new provider began furnishing services to Medicare patients. Internet-based enrollment for providers in some states became available in December 2008 and continues phase in during 2009.
Ms. McCune is vice president of Corcoran Consulting Group. Contact her at DMcCune@corco ran ccg.com.
