Medicare Physician Fee Schedule Full of Surprises

Bill Tracking SpyglassBy: Jeff Cohen

When new healthcare regs come out, we all get excited.  “What sort of nuggets will I find that could be useful?”  Sometimes the regs have useful things and sometimes, they’re just disappointing and frustrating.  The proposed changes to the 2016 Medicare Physician Fee Schedule are a mixed bag.  Allow me to illustrate:

The incident to rules may be changed to require only the ordering physician to supervise the performance of the service.  Currently, any physician in a group practice could supervise the performance of an incident to service (which allows the practice to bill for the service as though it had been performed by the ordering physician);

Qualified telemedicine services that are furnished via an interactive telecom system can be furnished by a physician or authorized practitioner for an additional list of services, including CRNAs.  This is a big change that expands the list of authorized providers;

The feds propose to characterize certain Stark Law violations as “technical,” which means they pose no financial risk to the Medicare program.  Examples include unsigned or expired agreements;

Specifies a method of permissible financial assistance by hospitals to assist with a physician or medical practice recruiting non-physician practitioners.  Stark’s only relevant provision currently applies only to physician recruitment, and this change should help physicians and hospitals alike;

Stark would be modified to loosen its application to certain test/procedures collection, transportation, process and storage arrangements;

Stark would also be modified to specify an exception for certain “timeshare” (part time use) arrangements involving hospitals and physicians where the physicians is the licensee who has exclusive dominion and control of the property being used by the physician (but not clinical labs);

Parties looking for new ways of addressing old challenges would be well served to review the proposed regulatory changes and to offer their insight and opinion on those changes which affect them.  The deadline for submitting comments regarding the proposed rule is September 8, 2015!


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