Ophthalmology and Optometry Coding Alert

New Medicare Physician Fee Schedule proposal brings pay raise next year.

For the first time in years, practices didn’t open the Medicare Physician Fee Schedule proposal to learn about whether devastating conversion factor cuts would impact their payments. Thanks to the new “doc fix” Medicare payment model that the HHS announced in January, you won’t face a 20-plus percent cut in January like in previous years – in fact, you’ll get your second scheduled 0.5 percent pay increase on Jan. 1 (the first increase kicked in on July 1).

“This is the first rule that CMS has done regarding physician fees since the repeal of the SGR that many of us have been working on for several years,” said CMS’s Sean Cavanaugh during a July 14 Open Door Forum.

On July 8, CMS released the proposed Medicare Physician Fee Schedule that it created for the 2016 payment year. Although you won’t face payment insecurity issues, you will see some changes – and whether they’re good or bad depends on your practice mix.

Get Ready for Potential Incident-To Adjustments

If you’ve got the incident-to rules for Part B memorized, it could be time to commit a new set of regulations to memory. The proposal suggests changes to the incident to rules, which allow a non-physician practitioner (NPP) to bill under the doctor’s ID number and collect a full fee rather than submitting claims under the NPP’s number and collecting 15 percent less.

Current way: Right now if you bill incident to, any doctor in the office can be listed on the claim as the person providing direct supervision for the NPP who is performing the service.

Proposed 2016 way: In the proposed fee schedule, CMS suggests only paying for incident to services if the doctor who bills for the incident to service is the same person directly supervising the care.

“To be certain that the incident to services furnished to a beneficiary are in fact an integral, although incidental, part of the physician’s or other practitioner’s personal professional service that is billed to Medicare, we believe that the physician or other practitioner who bills for the incident to service must also be the physician or other practitioner who directly supervises the service,” CMS says in the proposed rule.

In addition, CMS is proposing that the person providing the incident to service does so in accordance with state law and is licensed to do it. The incident to provider also cannot have been excluded from any federal health care program or have had their enrollment revoked for any reason. In other words, just because the service is billed under a supervising doctor’s number doesn’t mean the performing NPP can be excluded from Medicare.