It has been a busy, though productive year from a Practice Management standpoint. I would like to thank the members of the committee, who have worked hard and have done a diligent job at responding to the challenges facing our members. There are some specific points for consideration that are likely pertinent to the majority of our membership:
Federal Budget Concerns:
Some have inquired about the implica- tions of the government shutdown on reimbursement and clinical care. First, it is unclear as to whether federal budget will be resolved at the time of this publication. In prior similar budgetary shutdowns, reimbursement from CMS has been held or delayed while the final budgetary al- location has been resolved. However, in this budgetary cycle, the Department of Health and Human Services has already been largely funded on a prior budget allocation. As a result, federal payors such as Medicare and Medicaid have remained open and funded, and we anticipate con- tinued reimbursements for clinical services to be provided on time.
While the National Institutes of Health have been largely running as scheduled, some other federal agencies such as the Food and Drug Administration (FDA) have been affected. Research funding requests and reviews through the FDA has been largely on hold, as well as many applica- tions for new drug approvals. While it remains to be seen how this will affect custom device applications and exemp- tions, we do anticipate some potential delays for these requests. Please let us know if there are any concerns or delays in these regards.
New Codes:
New CPT codes have been added for 2019, including some specific codes that are relevant to musculoskeletal oncology. In
particular, structural allograft codes have now been valued and included into the CPT manual. These include:
20932 Allograft, includes templating, cutting, placement and internal fixation, when performed; osteoarticular, including articular surface and contiguous bone (List separately in addition to code for primary procedure).
20933 hemicortical intercalary, partial (i.e., hemicylindrical) (List separately in addition to code for primary procedure).
20934 intercalary, complete (i.e., cylindrical) (List separately in addition to code for primary procedure).
In addition, we have been working with the AAOS and representing our member- ship regarding changes to codes related to antibiotic cement implants as well as primary arthroplasty. Updates will be provided as further details emerge.
Medicare Physician Fee Schedule:
We have been working in close conjunction with the AAOS and the AMA regarding a response to the proposed changes to the Medicare Physician Fee Schedule (MPFS). Some regulations regarding the documen- tation requirements have already gone into effect for 2019, such as easing the need to restate information that is already available within the medical record. The bulk of the MPFS Final Rule will not be implemented until 2021, regarding the CMS reimbursement for Evaluation and Management (E&M) services.
Over the next 2 years, we will continue to work with the AMA on recommendations for adjusting the guidelines for E&M level of service (LOS). We anticipate that E&M LOS determination will be more closely related to medical decision making, with less emphasis upon history and physical examination points documented. It does appear that CMS will contract the wRVU for E&M Levels 2-4, starting in 2021, how- ever. More information will follow as they become available.
Please let us know if there are any prob- lems or concerns related to Practice Man- agement, as well as additional information that may be helpful for your practices, so that we can best suit your interests and needs.