# 2015 Physician Final Rule



## dwaldman (Nov 3, 2014)

Below some things that I noticed when I scrolled through 2015 Physician final rule. Thought I would share some notable changes.

http://www.ofr.gov/OFRUpload/OFRData/2014-26183_PI.pdf 


Page 743-744 Measure 30 will be remove in 2015

Perioperative Care: Timing of Prophylactic Antibiotic?Administering Physician: Percentage of surgical patients aged 18 years and older who receive an anesthetic when undergoing procedures with the indications for prophylactic dministration of a prophylactic parenteral antibiotic ordered has been initiated within 1 hour (if fluoroquinolone or vancomycin, 2 hours) prior to the surgical incision (or start of procedure when no incision is required)  
Commenters disagreed with CMS? proposal to remove this measure noting ?it is premature to remove a measure based on a high-performance rate when the EP reporting rate within the PQRS program is low.? With a performance rate above 90 percent for multiple consecutive years, CMS considers the measure to have reached its potential, and no longer represents a clinical performance gap that should be measured by the PQRS Program.  Additionally, CMS will apply the Measure Applicability Validation (MAV) process for claims-based reporting in those cases where specialists do not have enough relevant measures to report. For this reason, CMS is finalizing its proposal to remove this measure from reporting in 2015 PQRS
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(2) Epidural Injection and Fluoroscopic Guidance − CPT Codes 62310, 62311, 62318, 62319, 77001, 77002 and 77003 
For CY 2014, we established interim final rates for four epidural injection procedures, CPT codes 62310 (Injection(s), of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), not including neurolytic substances, including 
needle or catheter placement, includes contrast for localization when performed, epidural or subarachnoid; cervical or thoracic), 62311 (Injection(s), of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), not including neurolytic 
substances, including needle or catheter placement, includes contrast for localization when performed, epidural or subarachnoid; lumbar or sacral (caudal)), 62318 (Injection(s), including indwelling catheter placement, continuous infusion or intermittent bolus, of diagnostic or therapeutic substance(s) (including anesthetic, antispasmodic, opioid, steroid, other solution), not including neurolytic substances, includes contrast for localization when performed, epidural or subarachnoid; cervical or thoracic) and 62319 (Injection(s), including indwelling catheter placement, continuous infusion or intermittent bolus, of diagnostic or therapeutic substance(s) 
(including anesthetic, antispasmodic, opioid, steroid, other solution), not including neurolytic 
 substances, includes contrast for localization when performed, epidural or subarachnoid; lumbar or sacral (caudal)).  These interim final values resulted in CY 2014 payment reductions from the CY 2013 rates for all four procedures. 
In the CY 2014 final rule with comment period (78 FR 74340), we described in detail our interim valuation of these codes.  We indicated we established interim final work RVUs for these codes that were less than those recommended by the RUC because we did not believe that the 
RUC-recommended work RVUs accounted for the substantial decrease in time it takes to furnish these services as reflected in the RUC survey data for these four codes.  Since the RUC provided no indication that the intensity of the procedures had changed, we indicated that we believed the 
work RVUs should reflect the reduction in time.  We also established interim final direct PE inputs for these four codes based on the RUC-recommended inputs without any refinement.  These recommendations included the removal of the radiographic-fluoroscopy room for CPT codes 62310, 62311, and 62318 and a portable C-arm for CPT code 62319.  In response to the comments we received objecting to the CY 2014 interim final values for these codes, we looked at other injection procedures.  Other injection procedures, including 
some that commenters recommended we use to value these epidural injection codes, include the work and practice expenses of image guidance in the injection code.  In the proposed rule, we detailed many of these procedures, which include the image guidance in the injection CPT code.  
Since our analysis of the Medicare data and comments received on the CY 2014 final rule with comment period indicated that these services are typically furnished with imaging guidance, we believe it would be appropriate for the codes to be bundled and the inputs for image guidance to 
be included in the valuation of the epidural injection codes as it is for transforaminal and paravertebral codes.  We stated that we did not believe the epidural injection codes can be appropriately valued without considering the image guidance, and that bundling image guidance will help assure relativity with other injection codes that include the image guidance.  To 
determine how to appropriately value resources for the combined codes, we indicated that we believed more information is needed.  Accordingly, we proposed to include CPT codes 62310, 62311, 62318, and 62319 on the potentially misvalued code list so that we can obtain information to value them with the image guidance included.  In the meantime, we proposed to 
use the CY 2013 input values for CPT codes 62310, 62311, 62318 and 62319 to value these codes for CY 2015.  Specifically, we proposed to use the CY 2013 work RVUs and work times.    Because it was clear that inputs that are specifically related to image guidance, such as the radiographic fluoroscopic room, are included in these proposed direct PE inputs for the epidural injection codes, we believed allowing separate reporting of the image guidance codes 
would overestimate the resources used in furnishing the overall service.  To avoid this situation, we also proposed to prohibit the billing of image guidance codes in conjunction with these four epidural injection codes.  We stated that we believed our two-tiered proposal to utilize CY 2013 input values for this family while prohibiting separate billing of imaging guidance best ensures 
that appropriate reimbursements continue to be made for these services, while we gather additional data and input on the best way to value them through codes that include both the injection and the image guidance.  
Comment:  The commenters did not object to identifying these codes as potentially misvalued and generally agreed with our proposal to revert to the 2013 inputs for CY 2015.  
Response:  We appreciate support for our proposal.  
Comment:  Several commenters agreed that it would be appropriate to bundle the image guidance with the epidural procedures.  Other commenters suggested that we create both a bundled code and a stand-alone epidural injection code. 
Response:  We appreciate commenters? support for our proposal to bundle image guidance with the epidural procedures.  As part of the review process, consideration can be given to how to best implement bundled codes. 
Comment:  Other commenters expressed concern that the bundling approach CMS proposed to use until these codes are reviewed did not incorporate the work or time for fluoroscopy.  Some requested that we add the payment for fluoroscopic guidance to the epidural injection codes, as we have done in the past for facet joint injections and other services.  
Commenters requested that we continue to allow the image guidance codes to be separately billed until these services are revalued.  Another commenter suggested that it may be premature to prohibit separate billing for image guidance, as there is considerable variation on the use of 
fluoroscopic guidance between codes within this family. 
Response:  We understand commenters? concerns about our proposal to prohibit separate billing for image guidance, and note that these concerns are part of the reason we are referring these codes to the RUC as potentially misvalued.  However, given that significant resources are 
allocated to fluoroscopic guidance within the current injection codes, we do not believe it is appropriate to continue to allow the image guidance to be separately billed while we evaluate these epidural injection codes as potentially misvalued services.    
After considering comments received, we are finalizing CPT codes 62310, 62311, 62318, and 62319 as potentially misvalued, finalizing the proposed RVUs for these services, and prohibiting separate billing of image guidance in conjunction with these services. 

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On page 93, they describe deleting POS 22 and replacing it with 2 new place of services.

Page 159 Removal of 10 day global in 2017 and 90 day global in 2018

Page 679 describes requiring 1 cross cutting measure for PQRS claims/registry. Summary of PQRS requirements seen on 708. Table 52 Cross Cutting Measures found on page 718. 


Page 739 States the pneumonia vaccination measure will have the NQSD changed


Page 743, Measure 20 will be remove in 2015


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## KMCFADYEN (Nov 5, 2014)

Are there any procedures that do not include flouro in 2015?


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## jcisne (Nov 5, 2014)

Thanks for posting!! My physician does a lot of the 62310-62311 injections.


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## marvelh (Nov 7, 2014)

Remember though that just because Medicare has bundled image guidance for epidural injections for 2015 does not necessarily mean that will be applicable for all payers.  The concept of separately billing for fluoroscopy with the 62310-62319 code set when used for image guidance remains in the 2015 CPT code book.


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