2009 MPFS final regulations

The 2009 Medicare Physician Fee Schedule regulation was released in final form yesterday (on display), and will be published in the Federal Register on November 19.  It is chock full of payment and policy changes, detailed in three CMS fact sheets: (1) payment policies and rates; (2) MIPPA-related changes; and (3) e-prescribing incentives and PQRI updates.

A few highlights:

• MIPPA's 1.1 % MPFS rate increase in lieu of the previously-scheduled SGR pay cut
• Deferral of the proposed incentive payment and shared savings (gainsharing) Stark exception, together with a call for further comment
• Revision of the anti-markup rule
• Roll-out of IDTF standards and enrollment requirements to all physician-based and non-physician-practitioner-(NPP)-based IDTF-like services (with accommodation made for mobile IDTFs that operate "under arrangements" with hospitals)
  
• Imaging accreditation and appropriateness criteria under MIPPA (follow link to earlier HealthBlawg post on the subject)
  
• E-prescribing incentives — available under MIPPA — phases down from a bonus in the first five years for early adopters (2% in year 1, less as time goes by) to a penalty thereafter (ramps up over time to a 2% penalty) to drag the last holdouts, kicking and screaming, into the system
• 52 more PQRI measures — 153 and counting — for the CMS pay-for-reporting system, with a bump up in to potential bonus from 1.5% to 2% (also thanks to MIPPA)

David Harlow
The Harlow Group LLC
Health Care Law and Consulting

Updated 11/3/08