CMS proposed blending of E/M codes could disproportionately affect nephrology payment vs other specialties
Nephrologists would see less than a percentage point change in Medicare payments for dialysis services in 2019 based on a proposed rule CMS released on July 11.
The agency is proposing a change in the Medicare Physician Fee Schedule (MPFS) regarding payments for evaluation and management (E/M) levels of care, offering a blended payment for some codes within E/M levels 2-5, according to the proposed rule. CMS estimates that the change will be less than a 3% reduction in the $2.285 million that is paid out currently for nephrology E/M services.
“While the cuts in payments for high level services is balanced somewhat by a reduction in the documentation burden for these services, the proposed changes will have a disproportionately negative impact on specialties treating patients with chronic illnesses such as nephrology,” Robert Blaser, director of public policy for the Renal Physicians Association, wrote in a recent edition of RPA Weekly News.
Blaser wrote that the E/M code adjustments and other changes in the MPFS mean the nephrology specialty “will experience a 1% reduction in payments in 2019. However, the conversion factor for 2019 is scheduled to be increased by about $0.06 to $36.05, and this combined with increases in the relative value units (RVUs) for all of the dialysis codes, inpatient and outpatient, adult and pediatric, in-center and home, means that reimbursement for all of those services will increase at least incrementally in 2019.”
Blaser noted the RPA would be taking a closer look at the proposed rule in the coming weeks.
Other provisions of benefit to nephrologists in the proposed rule are regulations allowing the use of telehealth services for patients on home dialysis with the home as a telehealth site. Under the proposed rule, nephrologists can provide two of three monthly home dialysis visits in a 3-month period using telehealth. A patient’s home and the dialysis facility are now both included as approved originating sites. That was finalized based on amendments to the Bipartisan Budget Act of 2018 “that allow an individual determined to have end-stage renal disease receiving home dialysis to choose to receive certain monthly end-stage renal disease-related (ESRD-related) clinical assessments via telehealth on or after Jan. 1, 2019,” according to the proposed rule. “The new section 1881(b)(3)(B)(ii) of the act requires that such an individual must receive a face-to-face visit, without the use of telehealth, at least monthly in the case of the initial 3 months of home dialysis and at least once every 3 consecutive months after the initial 3 months.”
The physician community has until Sept. 10 to respond to the proposed rule. Information on how to submit a response is available at www.regulations.gov.