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  • Final Fee Schedule Rule a Mixed Bag; Outpatient Rule More Positive

    The US Centers for Medicare and Medicaid Services (CMS) has issued final rules for the 2018 Medicare physician fee schedule (PFS) and outpatient prospective payment system (OPPS) that don't vary significantly from the proposed rules released earlier in the year—except when it comes to 1 element involving the current procedural terminology (CPT) codes.

    As in the initial proposal, work relative value units (RVUs) for CPT codes will be maintained under the PFS as per recommendations from an American Medical Association review panel. However, CMS has changed its approach to practice expense RVUs: instead of maintaining those RVUs at 2017 levels as proposed, the agency will adopt the panel's recommendation for some reductions. APTA staff are analyzing the entire rule and will issue a detailed summary in the coming days that will clarify the impact those reductions might have. CMS has issued a fact sheet on the final rule.

    Taken as a whole the final PFS rule contains more good news than bad in the wake of a lengthy review of multiple CPT codes—many of which commonly are used in physical therapy—as potentially "misvalued." The review had put those codes at risk of sizable reductions for both work and practice expense RVUs. While some practice expense RVUs may drop, the final rule includes no cuts to the work RVUs and actually increases values for a few. Initial analysis indicates that overall, the increases and cuts likely balance out.

    More positive news related to the fee schedule: CMS will increase the therapy cap from $1,980 to $2,010 beginning in 2018. The therapy cap landscape could be seeing further changes, however, pending the outcome of an effort in Congress to repeal some elements of the therapy cap process.

    The PFS announcement comes on the heels of a final OPPS rule that also includes provisions supported by APTA—particularly moves toward reimbursement for outpatient-based total knee arthroplasty (TKA) and "non-enforcement" of direct supervision requirements for outpatient therapeutic services delivered in designated critical access hospitals and rural hospitals with fewer than 100 beds. The final rule also mirrors the proposed rule's overall 2% payment increase for outpatient hospitals and a 1.9% boost for ambulatory surgical centers. A detailed APTA summary of the OPPS rule also is in the works. CMS has issued a fact sheet on the final rule.