[Federal Register: June 5, 1998 (Volume 63, Number 108)]
[Proposed Rules]
[Page 30817-30866]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr05jn98-45]
[[Page 30817]]
_______________________________________________________________________
Part II
Department of Health and Human Services
_______________________________________________________________________
Health Care Financing Administration
_______________________________________________________________________
42 CFR Parts 405, et al.
Medicare Program; Revisions to Payment Policies Under the Physician Fee
Schedule for Calendar Year 1999; Proposed Rule
[[Page 30818]]
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Health Care Financing Administration
42 CFR Parts 405, 410, 413, 414, 415, 424, and 485
[HCFA-1006-P]
RIN 0938-AI52
Medicare Program; Revisions to Payment Policies Under the
Physician Fee Schedule for Calendar Year 1999
AGENCY: Health Care Financing Administration (HCFA), HHS.
ACTION: Proposed rule.
-----------------------------------------------------------------------
SUMMARY: This proposed rule would make several policy changes affecting
Medicare Part B payment. The changes that relate to physician services
include: resource-based practice expense relative value units, medical
direction rules for anesthesia services, and payment for abnormal Pap
smears. Also, we would rebase the Medicare Economic Index from a 1989
base year to a 1996 base year. Under the law, we are required to
develop a resource-based system for determining practice expense
relative value units. The Balanced Budget Act of 1997 (BBA 1997)
delayed, for 1 year, implementation of the resource-based practice
expense relative value units until January 1, 1999. Also, BBA 1997
revised our payment policy for nonphysician practitioners, for
outpatient rehabilitation services, and for drugs and biologicals not
paid on a cost or prospective payment basis. In addition, BBA 1997
permits certain physicians and practitioners to opt out of Medicare and
furnish covered services to Medicare beneficiaries through private
contracts. In addition, since we established the physician fee schedule
on January 1, 1992, our experience indicates that some of our Part B
payment policies need to be reconsidered. This proposed rule is
intended to correct inequities in physician payment and solicits public
comments on specific proposed policy changes.
DATES: Comments on the proposed resource-based practice expense policy
will be considered if we receive them at the appropriate address, as
provided below, no later than 5 p.m. on September 3, 1998. Comments on
all other issues will be considered if we receive them at the
appropriate address, as provided below, no later than 5 p.m. on August
4, 1998.
ADDRESSES: Mail written comments (1 original and 3 copies) to the
following address: Health Care Financing Administration, Department of
Health and Human Services, Attention: HCFA-1006-P, P.O. Box 26688,
Baltimore, MD 21207-0488.
If you prefer, you may deliver your written comments (1 original
and 3 copies) to one of the following addresses:
Room 309-G, Hubert H. Humphrey Building, 200 Independence Avenue, SW.,
Washington, DC 20201, or
Room C5-09-26, 7500 Security Boulevard, Baltimore, MD 21244-1850
Because of staffing and resource limitations, we cannot accept
comments by facsimile (FAX) transmission. In commenting, please refer
to file code HCFA-1006-P. Comments received timely will be available
for public inspection as they are received, generally beginning
approximately 3 weeks after publication of a document, in Room 309-G of
the Department's offices at 200 Independence Avenue, SW., Washington,
DC, on Monday through Friday of each week from 8:30 a.m. to 5 p.m.
(phone: (202) 690-7890).
Copies: To order copies of the Federal Register containing this
document, send your request to: New Orders, Superintendent of
Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954. Specify the date
of the issue requested and enclose a check or money order payable to
the Superintendent of Documents, or enclose your Visa or Master Card
number and expiration date. Credit card orders can also be placed by
calling the order desk at (202) 512-1800 or by faxing to (202) 512-
2250. The cost for each copy is $8. As an alternative, you can view and
photocopy the Federal Register document at most libraries designated as
Federal Depository Libraries and at many other public and academic
libraries throughout the country that receive the Federal Register.
This Federal Register document is also available from the Federal
Register online database through GPO Access, a service of the U.S.
Government Printing Office. Free public access is available on a Wide
Area Information Server (WAIS) through the Internet and via
asynchronous dial-in. Internet users can access the database by using
the World Wide Web; the Superintendent of Documents home page address
is http://www.access.gpo.gov/su__docs/, by using local WAIS client
software, or by telnet to swais.access.gpo.gov, then login as guest (no
password required). Dial-in users should use communications software
and modem to call 202-512-1661; type swais, then login as guest (no
password required).
FOR FURTHER INFORMATION CONTACT: Roberta Epps, (410) 786-4503 (for
issues related to outpatient rehabilitation services, nurse
practitioners, clinical nurse specialists, and certified nurse-
midwives).
Stephen Heffler, (410) 786-1211 (for issues related to the Medicare
Economic Index).
Anita Heygster, (410) 786-4486 (for issues related to private
contracts).
Jim Menas, (410) 786-4507 (for issues related to Pap smears and
medical direction for anesthesia services).
Robert Niemann, (410) 786-4569 (for issues related to the drugs and
biologicals policy).
Regina Walker-Wren, (410) 786-9160 (for issues related to physician
assistants).
Stanley Weintraub, (410) 786-4498 (for issues related to practice
expense relative value units and all other issues).
SUPPLEMENTARY INFORMATION: To assist readers in referencing sections
contained in this preamble, we are providing the following table of
contents. Some of the issues discussed in this preamble affect the
payment policies but do not require changes to the regulations in the
Code of Federal Regulations. Information on the regulation's impact
appears throughout the preamble and not exclusively in part V.
Table of Contents
I. Background
A. Legislative History
B. Published Changes to the Fee Schedule
II. Specific Proposals for Calendar Year 1999
A. Resource-Based Practice Expense Relative Value Units
1. Current Practice Expense Relative Value Unit System
2. Criticism of Current Practice Expense Relative Value Unit
System
3. Resource-Based Practice Expense Legislation
4. Originally Proposed Methodology for Developing Resource-Based
Practice Expense Relative Value Units
5. Balanced Budget Act of 1997 Provisions Pertaining to
Resource-Based Practice Expense Relative Value Units
6. HCFA Response to BBA 1997 Requirements
7. Summary of General Input from the Medical Community and
Comments from the October 1997 Notice with Comment Period
8. Issues Considered in Developing New Practice Expense RVUs
9. Alternative Practice Expense Methodologies Considered
10. Description of the Proposed Methodology for Developing
Practice Expense Relative Value Units
a. Overview
b. Data Sources
c. Practice Expense Cost Pools
d. Cost Allocation Methodology
[[Page 30819]]
11. Comments of the American Medical Association Regarding the
Use of the Socioeconomic Monitoring System Survey Data to Construct
Practice Expense Relative Value Units
12. Other Methodological Issues
a. Professional and Technical Component Services
b. Practice Expenses per Hour Adjustments and Specialty
Crosswalks
c. Time Associated with the Work Relative Value Units
13. Other Practice Expense Policies
a. Site-of-Service Payment Differential
b. Additional Relative Value Units for Additional Office-Based
Expenses for Certain Procedure Codes
c. Anesthesia Services
14. Refinement
a. Issues Involved in Refinement
b. Example of the Process for Reviewing and Commenting on
Practice Expense Relative Value Units
c. Information on Accessing Data Files on HCFA's Homepage
15. Reductions in Practice Expense Relative Value Units for
Multiple Procedures
16. Transition
17. Proposed Regulation Revisions
18. Response to GAO Recommendations
B. Medical Direction for Anesthesia Services
C. Separate Payment for Physician Interpretation of an Abnormal
Papanicolaou Smear
D. Rebasing and Revising the Medicare Economic Index
1. Background
a. History
b. Use of Current Data
2. Rebasing and Revising Expense Categories
a. American Medical Association Socioeconomic Monitoring System
Survey
b. Employment Cost Index Survey
c. Asset and Expenditure Survey
d. Current Population Survey
e. Medical Economics Continuing Survey
3. Selection of Price Proxies
a. Background
b. Expense Categories
(1) Physician's Time
(2) Nonphysician Employee Compensation
(3) Office Expense
(4) Medical Materials and Supplies
(5) Professional Liability Insurance
(6) Medical Equipment
(7) Other Professional Expenses
4. Summary of Changes
III. Implementation of the Balanced Budget Act of 1997
A. Payment for Drugs and Biologicals
B. Private Contracting with Medicare Beneficiaries
C. Payment for Outpatient Rehabilitation Services
1. Overview of Policies Before BBA 1997
a. Coverage
b. Providers of Outpatient Rehabilitation Services
c. Payment for Services
(1) Reasonable Cost-Based Payments
(2) Fee Schedule Payments
d. Financial Limitation
2. BBA Provisions Affecting Payment for Outpatient
Rehabilitation Services
a. Reasonable Cost-Based Payments
b. Prospective Payment System for Outpatient Rehabilitation
Services
(1) Overview
(2) Services Furnished by Skilled Nursing Facilities
(3) Services Furnished by Home Health Agencies
(4) Services Furnished by Comprehensive Outpatient
Rehabilitation Facilities
(5) Site-of-Service Differential
(6) Mandatory Assignment
3. Uniform Procedure Codes for Outpatient Rehabilitation
Services
4. Financial Limitation
5. Qualified Therapists
6. Plan of Treatment
D. Payment for Services of Certain Nonphysician Practitioners
and Services Furnished Incident to their Professional Services
1. Coverage and Payment for Nurse Practitioner Services Before
BBA 1997
2. Coverage and Payment for Nurse Practitioner Services
Subsequent to BBA 1997
3. Coverage and Payment for Clinical Nurse Specialist Services
Before BBA 1997
4. Coverage and Payment for Clinical Nurse Specialist Services
Subsequent to BBA 1997
5. Coverage and Payment for Certified Nurse-Midwife Services
6. Coverage and Payment for Physician Assistant Services Before
BBA 1997
7. Coverage and Payment for Physician Assistant Services
Subsequent to BBA 1997
IV. Collection of Information Requirements
V. Response to Comments
VI. Regulatory Impact Analysis
A. Regulatory Flexibility Act
B. Resource-Based Practice Expense Relative Value Units
C. Medical Direction for Anesthesia Services
D. Separate Payment for Physician Interpretation of an Abnormal
Papanicolaou Smear
E. Rebasing and Revising the Medicare Economic Index
F. Payment for Nurse Midwives' Services
F. Payment for Drugs and Biologicals
G. BBA 1997 Provisions Included in This Proposed Rule
1. Payment for Services of Certain Nonphysician Practitioners
and Services Furnished Incident to Their Professional Services
2. Payment for Outpatient Rehabilitation Services
3. Payment for Drugs and Biologicals
4. Private Contracting with Medicare Beneficiaries
H. Impact on Beneficiaries
Addendum A--Description of Clinical Practice Expert Panel Data and
Methodology
Addendum B--Technical Description of the Proposed Methodology for
Developing Practice Expense Relative Value Units
Addendum C--Relative Value Units (RVUs) and Related Information
In addition, because of the many organizations and terms to
which we refer by acronym in this proposed rule, we are listing
these acronyms and their corresponding terms in alphabetical order
below:
AANA--American Association of Nurse Anesthetists
ABC--Activity based costing
ABN--Advance Beneficiary Notice
AHE--Average Hourly Earnings
AMA--American Medical Association
ASA--American Society of Anesthesiologists
AWP--Average Wholesale Price
BBA--Balanced Budget Act of 1997
BLS--Bureau of Labor Statistics
CF--Conversion factor
CFR--Code of Federal Regulations
CMSAs--Consolidated Metropolitan Statistical Areas
CORF--Comprehensive outpatient rehabilitation facility
CPEPs--Clinical Practice Expert Panels
CPI--Consumer Price Index
CPI-U--Consumer Price Index for All Urban Consumers
CPS--Current Population Survey
CPT--[Physicians'] Current Procedural Terminology [4th Edition,
1997, copyrighted by the American Medical Association]
CRNA--Certified Registered Nurse Anesthetist
DME--Durable medical equipment
DMEPOS--Durable medical equipment, prosthetics, orthotics, and
supplies
DRG--Diagnosis-related group
EAC--Estimated Acquisition Cost
ECI--Employment Cost Index
ES-202--Data--Bureau of Labor Statistics from State unemployment
insurance agencies
ESRD--End-stage renal disease
FDA--Food and Drug Administration
FMR--Fair market rental
GAAP--Generally accepted accounting principles
GAF--Geographic adjustment factor
GPCI--Geographic practice cost index
HCFA--Health Care Financing Administration
HCPCS--HCFA Common Procedure Coding System
HHS--[Department of] Health and Human Services
HMO--Health maintenance organization
HUD--[Department of] Housing and Urban Development
MEDPAC--Medicare Payment Advisory Commission
MEI--Medicare Economic Index
MGMA--Medical Group Management Association
MSA--Metropolitan Statistical Area
NAIC--National Association of Insurance Commissioners
NPI--National provider identifier
OBRA--Omnibus Budget Reconciliation Act
OTIP--Occupational therapist in independent practice
PC--Professional component
PMSA--Primary Metropolitan Statistical Area
PPI--Producer Price Index
PPS--Prospective payment system
PTIP--Physical therapist in independent practice
RUC--[AMA's Specialty Society] Relative [Value] Update Committee
[[Page 30820]]
RVU--Relative value unit
SMS--Socioeconomic Monitoring System
SNF--Skilled nursing facility
TC--Technical component
TEFRA--Tax Equity and Fiscal Responsibility Act
UPIN--Uniform provider identifier number
I. Background
A. Legislative History
Since January 1, 1992, Medicare has paid for physician services
under section 1848 of the Social Security Act (the Act), ``Payment for
Physicians' Services.'' This section contains three major elements: (1)
A fee schedule for the payment of physician services; (2) a sustainable
growth rate for the rates of increase in Medicare expenditures for
physician services; and (3) limits on the amounts that nonparticipating
physicians can charge beneficiaries. The Act requires that payments
under the fee schedule be based on national uniform relative value
units (RVUs) based on the resources used in furnishing a service.
Section 1848(c) of the Act requires that national RVUs be established
for physician work, practice expense, and malpractice expense.
Section 1848(c)(2)(B)(ii)(II) of the Act provides that adjustments
in RVUs because of changes resulting from a review of those RVUs may
not cause total physician fee schedule payments to differ by more than
$20 million from what they would have been had the adjustments not been
made. If this tolerance is exceeded, we must make adjustments to the
conversion factors (CFs) to preserve budget neutrality.
B. Published Changes to the Fee Schedule
We published a final rule on November 25, 1991 (56 FR 59502) to
implement section 1848 of the Act by establishing a fee schedule for
physician services furnished on or after January 1, 1992. In the
November 1991 final rule (56 FR 59511), we stated our intention to
update RVUs for new and revised codes in the American Medical
Association's (AMA's) Physicians' Current Procedural Terminology (CPT)
through an ``interim RVU'' process every year. The updates to the RVUs
and fee schedule policies follow:
<bullet> November 25, 1992, as a final notice with comment period
on new and revised RVUs only (57 FR 55914).
<bullet> December 2, 1993, as a final rule with comment period (58
FR 63626) to revise the refinement process used to establish physician
work RVUs and to revise payment policies for specific physician
services and supplies. (We solicited comments on new and revised RVUs
only.)
<bullet> December 8, 1994, as a final rule with comment period (59
FR 63410) to revise the geographic adjustment factor (GAF) values, fee
schedule payment areas, and payment policies for specific physician
services. The final rule also discussed the process for periodic review
and adjustment of RVUs not less frequently than every 5 years as
required by section 1848(c)(2)(B)(i) of the Act.
<bullet> December 8, 1995, as a final rule with comment period (60
FR 63124) to revise various policies affecting payment for physician
services including Medicare payment for physician services in teaching
settings, the RVUs for certain existing procedure codes, and to
establish interim RVUs for new and revised procedure codes. The rule
also included the final revised 1996 geographic practice cost indices
(GPCIs).
<bullet> November 22, 1996, as a final rule with comment period (61
FR 59490) to revise the policy for payment for diagnostic services,
transportation in connection with furnishing diagnostic tests, changes
in geographic payment areas (localities), and changes in the procedure
status codes for a variety of services.
<bullet> October 31, 1997, as a final rule with comment period (62
FR 59048) to revise the geographic practice cost index (GPCI),
physician supervision of diagnostic tests, establishment of independent
diagnostic testing facilities, the methodology used to develop
reasonable compensation equivalent limits, payment to participating and
nonparticipating suppliers, global surgical services, caloric
vestibular testing, and clinical consultations. The final rule also
implemented certain provisions of the Balanced Budget Act of 1997 (BBA
1997) (Public Law 105-33), enacted on August 5, 1997, and implemented
the RVUs for certain existing procedure codes and established interim
RVUs for new and revised procedure codes.
This proposed rule would affect the regulations set forth at 42 CFR
part 405, which consists of regulations on Federal health insurance for
the aged and disabled; part 410, which consists of regulations on
supplementary medical insurance benefits; part 414, which consists of
regulations on the payment for Part B medical and other health
services; part 415, which pertains to services furnished by physicians
in providers, supervising physicians in teaching settings, and
residents in certain settings; part 424, which pertains to the
conditions for Medicare payment; and part 485, which pertains to
conditions of participation: specialized providers.
II. Specific Proposals for Calendar Year 1999
A. Resource-Based Practice Expense Relative Value Units
1. Current Practice Expense Relative Value Unit System
The Act details the types of services that are paid under the
physician fee schedule. These include physician services, services and
supplies incident to a physician service, diagnostic x-ray tests,
diagnostic laboratory tests (excluding clinical laboratory tests), and
x-ray, radium, and radioactive isotope therapy. BBA 1997 added other
services such as certain preventive services. While some of these
services do not have work RVUs, all of the services have practice
expense and malpractice expense RVUs. (Physician anesthesia services
are included under the physician fee schedule but are paid under a
different payment methodology that uses a separate CF and allowable
base and time units. Physician anesthesia services do not have practice
expense and malpractice expense RVUs.) Payments for practice expense
RVUs account for approximately 41 percent of total physician fee
schedule payments.
In most cases, the current practice expense RVUs are calculated
based on a statutory formula. They are derived from the product of
``base allowed charges'' and service-specific practice expense
percentages. The base allowed charge is the national allowed charge for
the service furnished during 1991. The service-specific practice
expense percentage is a weighted average of the practice expense
percentages of the specialties performing the service.
For services furnished beginning with calendar year 1994 and whose
practice expense RVUs exceed 1994 work RVUs and are performed in the
office setting less than 75 percent of the time, practice expense RVUs
in each of 1994, 1995, and 1996 were reduced by 25 percent of the
amount they exceed the 1994 work RVUs. (Before 1998, practice expense
RVUs were not reduced to less than 128 percent of 1994 work RVUs.)
For services furnished beginning with calendar year 1998 whose
practice expense RVUs (determined for 1998) exceeded 110 percent of the
work RVUs and which were provided less than 75 percent of the time in
an office setting, the 1998 practice expense RVUs were reduced to a
number equal to 110 percent of the work RVUs. This limitation did not
apply to services that had a proposed resource-based practice expense
RVU in the June 18, 1997 proposed rule (62 FR 33158), which was
[[Page 30821]]
an increase from its 1997 practice expense RVU. For office visit
procedure codes performed beginning calendar year 1998, the practice
expense RVUs were increased by a uniform percentage to equal the
aggregate decrease in the practice expense RVUs for other services.
2. Criticism of Current Practice Expense Relative Value Unit System
A common criticism of the current practice expense RVU system is
that for many services the RVUs, which are based on charges under the
reasonable charge system, are not based directly on the resources
involved with furnishing the service. Rather, the charge-based nature
of the current fee schedule practice expense retains historical charge
patterns that existed before the implementation of the physician fee
schedule on January 1, 1992. Those charge patterns favor procedures and
tests performed in hospitals rather than evaluation and management
services and other office-based services.
For example, a primary care physician would have to bill CPT code
99213 (level 3 office visit, established patient) approximately 80
times to collect the same amount of practice expense payments as a
cardiac surgeon would for performing one coronary artery bypass graft
with three coronary venous grafts (CPT code 33512), although the
practice expenses the surgeon typically incurs for the cardiac surgery
are primarily related to the pre- and postoperative services furnished
in the office, administrative costs, and overhead. The costs for
clinical staff, medical supplies, and medical equipment furnished to
hospital patients are included in the diagnosis-related group (DRG)
payment made to the hospital as required by section 1862(a)(14).
In their 1993 annual report to the Congress, the Physician Payment
Review Commission recommended that the Congress revise the practice
expense component of the physician fee schedule so that it is resource-
based. They further recommended that we collect data regarding the
direct cost incurred in delivering each service and that a formula-
based approach be used to allocate indirect costs. This recommendation
was instrumental in the Congress' legislating the resource-based
practice expense component.
3. Resource-Based Practice Expense Legislation
Section 121 of the Social Security Act Amendments of 1994 (Public
Law 103-432), enacted on October 31, 1994, requires us to develop a
methodology for a resource-based system for determining practice
expense RVUs for each physician service. In developing the methodology,
we must consider the staff, equipment, and supplies used in providing
medical and surgical services in various settings. The legislation
required the new payment methodology to be effective for services
furnished in 1998.
The legislation specifically requires that, in implementing the new
system of practice expense RVUs, we must apply the same budget-
neutrality provisions that we apply to other adjustments under the
physician fee schedule.
Before publication of the final rule in October 1997, section 4505
of the BBA 1997 delayed initial implementation of resource-based
practice expense RVUs until 1999. It also required that we do the
following:
<bullet> Use, to the maximum extent practicable, generally accepted
cost accounting principles that recognize all staff, equipment,
supplies, and expenses, not solely those that can be linked to specific
procedures.
<bullet> Consult with organizations representing physicians
regarding methodology and data to be used.
<bullet> Develop a refinement method to be used during the
transition.
<bullet> Consider impact projections that compare new proposed
payment amounts to data on actual physician practice expenses.
4. Originally Proposed Methodology for Developing Resource-Based
Practice Expense Relative Value Units
To implement the October 1994 legislation, we published a proposed
rule on June 18, 1997 (62 FR 33158). In the proposed rule, we
established a framework in which practice expenses were divided into
direct and indirect costs. Direct costs are those costs that can be
directly attributed to providing a service, such as the cost of a
nurse's time (salary), medical supplies and equipment, administrative
costs of billing, record maintenance, and the scheduling of office
patients. Direct costs also include the physician's costs of office
staff time for scheduling appointments and billing and collection
activities associated with a medical procedure furnished in a hospital.
Indirect costs cannot be directly attributed to a specific service, and
include costs such as rent, utilities, office equipment and supplies,
and accounting and legal fees. The allocation of indirect costs to
specific products or services is a classic accounting problem. The
indirect costs are difficult to relate directly to a specific service
because they are incurred by the practice as a whole.
The June 1997 proposed rule (62 FR 33172) described the following
methodology for calculating the proposed direct practice expense RVUs.
<bullet> We calculated the total pool of practice expense RVUs for
1995 and divided it into direct and indirect practice expense pools
using the American Medical Association's (AMA's) Socioeconomic
Monitoring System (SMS) survey data and our 1995 national claims
history data. The national distribution of direct and indirect practice
expense RVUs was 55 percent direct practice expense RVUs and 45 percent
indirect practice expense RVUs.
<bullet> The underpinning for the proposed direct components of the
practice expense RVUs was the data reported by the Clinical Practice
Expert Panels (CPEPs) for clinical and administrative labor, medical
supplies, and medical equipment inputs. There were 15 CPEPs,
corresponding to the major medical specialties, which were made up of
nominees from all major specialty societies. (A description of the
CPEPs is contained in the June 1997 proposed rule (62 FR 33161).) (See
Addendum A for a detailed description of the CPEP process.)
<bullet> These data were edited to apply Medicare payment policy
rules to ensure that the reported data were consistent with our
national hospital and physician payment policies. The primary
adjustment was the removal of direct inputs recorded for clinical labor
staff, medical equipment, and medical supplies furnished to hospital
patients. Other adjustments were made for the professional component of
a service, the technical component of a service, and the combined
service, for codes that have an indicator of ZZZ under the physician
fee schedule, and for certain allergy and immunotherapy codes performed
on a per-test, per-dose, or per-vial basis.
<bullet> We believed that the relative relationships of the staff
time estimates within the individual CPEPs were generally correct but
that the absolute time estimates needed normalization. We placed the
codes from the different CPEPs on the same scale using a normalization
process that we call ``linking.'' Specifically, linking shifted an
entire CPEP's data relative to other CPEPs' data, based on the
relationship of the values assigned across panels for codes that had
been assigned to multiple CPEPs. We separately linked clinical and
administrative labor costs. Statistically, the linking was done using
regression methods.
[[Page 30822]]
<bullet> After the data were edited and linked, our physicians and
clinical staff analyzed the direct practice expense RVUs to determine
if there were unexplainable variations in the underlying CPEP data.
This review resulted in the application of two general reasonableness
rules. First, a decision was made to cap the administrative time of
several categories of service (services without a global period and
procedures subject to global periods with zero follow-up days) at the
administrative time assigned to CPT code 99213 (midlevel office
visits). Second, we decided to cap the nonphysician clinical staff time
at 1.5 times the physician time, in minutes, for performing the
procedure. Additional more specific rules were applied to certain
supplies and supply costs and for certain codes, such as psychotherapy,
physical therapy, chemotherapy, and nerve block codes.
<bullet> The aggregate percentage shares across all specialties of
labor and medical supplies and equipment from the CPEP data were scaled
to the percentage shares of these categories from the AMA's SMS survey
data. The CPEP expenses for labor, medical supplies, and medical
equipment were adjusted by scaling factors of 1.21, 1.06, and 0.39
respectively.
<bullet> The direct practice expense dollar amounts were converted
into direct practice expense RVUs. An adjustment factor of 0.65 was
used to convert the aggregate direct practice expense dollars to the
available Medicare direct practice expense dollars.
<bullet> Aggregate indirect practice expense RVUs were allocated to
individual codes based on the code-specific sum of the direct practice
expense, the malpractice expense, and the physician work RVU.
<bullet> The direct and the indirect practice expense RVUs per code
were combined to produce a single practice expense RVU per code.
Other practice expense proposals in the June 1997 proposed rule (62
FR 33160) included:
<bullet> Replacement of the current site-of-service differential
policy that systematically reduces the practice expense RVUs by 50
percent for certain procedures with a policy that would generally
identify two different levels (office or nonoffice) of practice expense
RVUs for each procedure code depending on the site of service.
<bullet> Elimination of the current policy that allows additional
practice expense RVUs for supplies that are used incident to a
physician service but were not the type of routine supplies included in
the current practice expense RVUs for specific services. These supplies
were included in the CPEP data for the specific procedure code.
<bullet> Reduction of the practice expenses for multiple
nonsurgical services performed at the same time as an evaluation and
management service.
The June 1997 proposed rule provided for a 60-day comment period
ending on August 18, 1997.
5. Balanced Budget Act of 1997 Provisions Pertaining to Resource-Based
Practice Expense Relative Value Units
On August 5, 1997, the President signed into law the Balanced
Budget Act of 1997 (BBA 1997). Section 4505(a) of BBA 1997 delayed the
effective date of the resource-based practice expense RVU system until
January 1, 1999. In addition, BBA 1997 provided for the following
revisions in the requirements to change from a charge-based practice
expense RVU system to a resource-based method.
Instead of paying for all services entirely under a resource-based
system in 1999, section 4505(b) of BBA 1997 provided for a 4-year
transition period. The practice expense RVUs for the year 1999 will be
the product of 75 percent of the previous year's RVUs (1998) and 25
percent of the resource-based RVUs. For the year 2000, the percentages
will be 50 percent charge-based and 50 percent resource-based. For the
year 2001, the percentages will be 25 percent charge-based and 75
percent resource-based. For subsequent years, the RVUs will be totally
resource-based.
Section 4505(c) of BBA 1997 required the Comptroller General to
review and evaluate our proposed rule and report to the Congress by
February 1998. The review was required to include an analysis of (1)
the adequacy of the data used in preparing the rule, (2) categories of
allowable costs, (3) methods for allocating direct and indirect
expenses, (4) the potential impact of the rule on beneficiary access to
services, and (5) any other matters related to the appropriateness of
resource-based methodology for practice expenses. The Comptroller
General was also to consult with representatives of physician
organizations with respect to matters of both data and methodology.
Section 4505(e) of BBA 1997 provided that, for 1998, the practice
expense RVUs be adjusted for certain services in anticipation of the
implementation of resource-based practice expenses beginning in 1999.
Practice expense RVUs for office visits were increased. For other
services whose practice expense RVUs (determined for 1998) exceeded 110
percent of the work RVUs and which were provided less than 75 percent
of the time in an office setting, the 1998 practice expense RVUs were
reduced to a number equal to 110 percent of the work RVUs. This
limitation did not apply to services that had a proposed resource-based
practice expense RVU in the June 1997 proposed rule that was an
increase from its 1997 practice expense RVU. The total of the
reductions was less than the statutory maximum of $390 million. The
procedure codes affected and the final RVUs for 1998 were published in
the October 31, 1997 final rule (62 FR 59103).
Section 4505(d)(2) of BBA 1997 required that the Secretary transmit
a report to the Congress by March 1, 1998, including a presentation of
data to be used in developing the practice expense RVUs and an
explanation of the methodology. A report was submitted to the Congress
in early March 1998. Section 4505(d)(3) requires that a proposed rule
be published by May 1, 1998, with a 90-day comment period. For the
transition to begin on January 1, 1999, a final rule must be published
by October 31, 1998.
BBA 1997 also required that we develop new resource-based practice
expense RVUs. In developing these new practice expense RVUs, section
4505(d)(1) required us to: (1) Utilize, to the maximum extent
practicable, generally accepted accounting principles that recognize
all staff, equipment, supplies, and expenses, not just those that can
be tied to specific procedures, and use actual data on equipment
utilization and other key assumptions; (2) consult with organizations
representing physicians regarding the methodology and data to be used;
and (3) develop a refinement process to be used during each of the 4
years of the transition period.
6. HCFA Response to BBA 1997 Requirements
BBA 1997 required us to develop new resource-based RVUs and to
consult with physician organizations regarding methodology and data. To
meet the BBA 1997 requirements and to promote input as we developed new
RVUs, we have sought and will continue to encourage maximum input from
those affected by this initiative. The following is a summary of
activities we have undertaken.
<bullet> Validation Panel Meetings.
We hosted 17 medical specialty panels that were charged with
validating the CPEP direct cost data for the high-volume CPT codes for
each specialty. All the major medical specialty societies were
represented, including nonphysician organizations.
[[Page 30823]]
Each panel, consisting of about 12 to 15 members, was made up of the
appropriate specialists, two general surgeons, two primary care
physicians, and two Medicare carrier medical directors. The panel
members reviewed and, if they believed necessary, revised the clinical
and administrative times and the supplies and equipment involved for
each code. Consensus within panels was reached on about 200 codes.
<bullet> Cross Specialty Panel.
Although the October validation panels were able to reach consensus
on many high-volume procedures within specific specialties, we were
concerned that there was not a uniform or consistent scale applied to
labor inputs across specialties. Therefore, in December, we convened a
multiple specialty panel of 37 panelists, including physicians,
nonphysicians, and administrators nominated by the specialty societies.
We expected the panel to help us achieve consistency across panels
on resource inputs, such as insurance billing and transcription times,
and to standardize the clinical staff types for similar classes of
services, whether they be registered nurses, medical assistants,
licensed practical nurses, or a mix of these staff types. The results
of the cross specialty panel were generally unsuccessful. While the
panel did provide the arena for panelists to furnish explanations of
times for activities that we believed to be excessive, the panelists
were generally reluctant to make any major modifications in the times
or staff they had assigned to their own services. The panelists could
not agree to any rules that would aid us in standardizing the data.
The panelists did recommend that we explore an option that treats
billing and insurance activities as indirect costs. Many panelists also
suggested that we proceed cautiously and try to minimize the magnitude
of redistribution.
<bullet> Indirect Cost Symposium.
We convened a meeting on November 21, 1997 on indirect practice
expenses to provide a forum for participants to discuss their preferred
methodology for allocating indirect costs. We asked those organizations
that commented on our proposed indirect cost methodology to make a
formal presentation of their views. All major medical specialty groups
were invited to attend and join in the discussion.
Some groups endorsed the methodology we proposed in the June 1997
proposed rule (62 FR 33172) with some modifications. One modification
recommended was to eliminate malpractice RVUs as a factor in allocating
indirect costs. It was noted, even by some advocates for other
allocation methods, that our proposed methodology embodied traditional
accounting methods for allocating indirect costs.
Only two major alternatives to our proposed methodology were
presented. The first, the Activity Based Costing (ABC) method, was
described as a cutting edge approach to determining the cost of
individual products (CPT codes). Under the ABC method, the total costs
of a practice are collected and assigned to discrete processes or
activities. These costs are then assigned to products to which they are
related.
The ABC method was developed for industries in which direct labor
(the traditional cost accounting method for allocating indirect costs)
is not the dominant factor in the production of the good or service.
This method is in the early developmental stages in medical practice
use.
The second alternative methodology presented was the physician work
RVU method of allocating indirect practice expenses. This method would
allocate indirect costs using only the physician work RVUs. However,
there did not appear to be much support for this methodology at the
meeting. It would, for example, penalize physician practices that have
proportionately higher equipment costs.
<bullet> October 31, 1997 Notice with Comment Period
<bullet> To inform all interested parties of our plans to issue a
new proposed rule and to request additional data from the medical
community to assist us in meeting BBA 1997 requirements, on October 31,
1997, we published a notice (62 FR 59267).
In that notice, we requested that physicians, physician
organizations, or others provide us with the following information:
<bullet> Generally accepted cost accounting principles--We
specifically requested information on the following: (1) Aspects of the
cost accounting methodology used in the June 1997 proposed rule that
were not consistent with the statutory guidance; and (2) complete
copies of studies of resource-based practice expense RVUs, including
any underlying surveys supporting these studies, performed by
physicians or physician groups or their contractors or consultants,
including pertinent details about the survey.
<bullet> Equipment utilization--We specifically requested complete
copies of any studies or other data showing the actual utilization of
equipment by physician practices, including pertinent details about the
survey, such as response rates, sampling design, methodology,
directions, and definitions.
<bullet> Other assumptions--We specifically requested information
regarding the useful life of equipment, the amount and percentage of
direct practice costs versus the amount and percentage of indirect
costs by specialty, and practice expense values for sites for which
values were not proposed in the June 1997 proposed rule (62 FR 33158).
<bullet> Use of physician-employed staff in hospitals and other
facility settings--We specifically requested comments and information
about the extent to which a physician employee, such as a registered
nurse, accompanies the physician to the hospital, ambulatory surgical
center, or other facilities to provide services, such as acting as an
assistant at surgery or serving as a scrub nurse. We asked for names of
specific facilities so that we might contact them in order to more
fully understand the nature of the relationships.
<bullet> Refinement process--We requested comments on how this
refinement process would operate including assigning practice expense
RVUs to new codes, who would be involved in the refinement process, and
how all of the users of the physician fee schedule would have access to
the process.
<bullet> Review of New Methodology by KPMG Peat Marwick LLP--Under
contract #500-97-0402, we requested that KPMG Peat Marwick LLP review
the practice expense per hour methodology. They concluded that the
methodology follows reasonable cost accounting principles. They made
this determination based on an examination of the available data
sources and a consideration of the cost and feasibility of acquiring
additional nationally representative data. As a future consideration,
they recommended sample validation of our cost allocation bases.
7. Summary of General Input From the Medical Community and Comments
From the October 1997 Notice With Comment Period
Some physicians, such as primary care physicians, expressed
satisfaction that the proposed methodology was generally sound. In
addition, the AMA was supportive of our panel process for direct
expenses and offered many helpful comments. However, many surgeons and
medical specialties argued that we should discard our current practice
expense data, and develop payments that reflect their ``actual costs.''
[[Page 30824]]
Both in written comments and in our meetings with the medical
community, we received much feedback on our methodology for indirect
practice expense. However, there was no consensus regarding methods for
allocating indirect costs to individual procedure codes.
In addition, we received 56 specific comments from individuals,
major organizations, and physician specialty groups on our October 1997
notice. The comments are summarized by the following categories:
<bullet> Generally Accepted Accounting Principles.
Some of the groups expected to experience an increase in payment
under the June 1997 proposed rule thought our approach satisfied the
current statutory mandate that we utilize generally accepted accounting
principles (GAAP). Those physician groups that expected to experience a
decrease in payments based on the methodology described in the June
1997 proposed rule said the approach in the proposed rule was
inconsistent with GAAP. They argued that GAAP requires us to use actual
practice expense data and said the data from the CPEPs and validation
panels were based on erroneous assumptions, or were unverified
approximations. At least five commenters supported using the activity-
based accounting approach.
<bullet> Equipment utilization.
Some groups furnished equipment-specific utilization levels for a
few services. Generally, the equipment and utilization levels were not
based on representative surveys of physicians performing the service.
Some suggestions were as follows:
------------------------------------------------------------------------
Percent
------------------------------------------------------------------------
Electroencephalography equipment........... 26
Electromyography........................... 36.5
Nerve Conduction Velocity.................. 36.5
Cystoscope................................. 5
Loop electrode excision procedure.......... 1
Colposcope................................. 1.6
YAG laser.................................. 12
ARGON laser................................ 5 to 6.4
Fundus camera.............................. 31.3
Spirometry and Ancillary Equipment......... 10 to 17
Bronchoscopy............................... 5 to 10
------------------------------------------------------------------------
<bullet> Useful Life.
We did not receive specific comments on suggested useful lives for
specific medical equipment, which is an important factor in estimating
equipment costs.
<bullet> Direct and Indirect Costs.
Some commenters pointed out that not all clinical labor can be
classified as direct costs. Tasks such as ordering supplies and
attending meetings or continuing education classes should be captured
as indirect costs. Some groups, including one primary care group, said
that billing costs should be an indirect expense, while others
supported maintaining them as direct costs. Many groups supported an
allocation process in which indirect costs are assigned based on a
specialty's specific indirect cost percentage. Only one group
specifically objected to this approach. Some physician groups provided
specific direct and indirect cost ratios based on limited surveys of
their membership.
<bullet> Employed Staff.
According to an American Hospital Association survey, 63 percent of
respondents (from 573 hospitals) believed that a physician brought
staff to the hospital during the last 6 months of 1996. Of these
respondents, 82 percent said this was not a regular practice.
Therefore, the American Hospital Association commented it is not a
typical practice in the United States for physicians to bring their own
staff to a hospital.
Five surgical specialties and subspecialties--neurosurgery,
ophthalmology, general thoracic surgery, congenital thoracic surgery,
and adult cardiac surgery--indicated that at least 50 percent of
practices use employed clinical staff in nonoffice settings. General
surgery indicated that 31 percent of general surgery practices pay for
clinical staff working in nonoffice settings. The Society of Thoracic
Surgeons stated that they do not have data on the number of clinical
nurses who work with thoracic surgeons in hospitals. However, they
stated that a survey of physician assistants shows that 72 percent of
physician assistants employed in cardiovascular surgery were employed
by solo or group physician practices.
According to the American Academy of Ophthalmology, 51 percent of
ophthalmologists bring equipment, such as keratomes, diamond knives,
cataract trays, and muscle trays to furnish services to hospital
patients.
<bullet> Refinement.
Most commenters support using the AMA's Specialty Society Relative
Value Update Committee's (RUC's) process to refine the practice expense
RVUs. (Currently the RUC recommends refinement of the physician work
RVUs.) Of these commenters, many recommended that the process include
nurses and practice managers, that there be established rules and
procedures for data collection, survey design, and response rates, and
that the process allows participation by subspecialties, such as
transplant surgeons and pediatric surgeons. One commenter suggested a
process using the AMA, Medical Group Management Association (MGMA), and
HCFA. Some commenters suggested using a RUC process only for new codes.
<bullet> Transition.
Several commenters stated that the base year for the transition
should be the 1997 practice expense RVUs and not the 1998 practice
expense RVUs. They suggested that the 1998 adjustment required by BBA
1997 is not intended to be included in the base for purposes of the
practice expense transition. Some commenters recommended that we
explore using ceilings and floors during the transition period or use
caution so as to limit the amount of the redistribution.
<bullet> Site-of-Service Differential.
Commenters from the American Academy of Orthopaedic Surgeons stated
that we need office practice expense RVUs for musculoskeletal system
surgery codes 25000, 25031, 26040, 26060, 26608, 29815 through 29848,
and 29870 through 29898. Some commenters believe we should develop
practice expense RVUs for all procedures at all sites and permit office
endoscopy only under very limited and clearly defined standards.
<bullet> Data Quality.
The American College of Surgeons stated that the CPEP data are
based on erroneous assumptions, educated guesses, and unverified
approximations. They stated that the data from panels are unreliable
for the administrative times for chiropractic manipulation, level 3
office visits, inpatient consultations, balloon angioplasty, and
clinical times for allergy skin testing.
<bullet> Validation.
The AMA stated that we should use AMA and MGMA data on full time
equivalent staff for each physician to assess how well various
methodological options account for total labor costs. The American
College of Physicians suggested we complete an impact analysis that
compares proposed practice expense payments to actual practice expenses
on a specialty by specialty basis, as well as sponsoring a study
requiring on-site visits to practices.
8. Issues Considered in Developing New Practice Expense RVUs
We faced the following major issues as we decided whether and how
to modify our original proposal for physician practice expense RVUs.
These issues arose from many sources: from concerns about the CPEP data
and our
[[Page 30825]]
original proposed methodology, from the requirements of BBA 1997, from
the findings and recommendations in the General Accounting Office's
Report to the Congress on physician practice expense, and from input we
received from the medical community.
<bullet> Purpose.
Our original practice expense proposal was based on the 1994
legislation, which stated that the new practice expense methodology
must consider the staff, equipment, and supplies used in the provision
of various medical and surgical services in various settings. We
interpreted this to mean that Medicare payments for each service should
be based on the relative resources typically and reasonably involved
with performing the service. We believed we could best calculate these
resources by achieving clinical consensus on the actual inputs it would
typically take to perform a given service. However, surgeons and some
other specialties contended that the purpose of a resource-based
practice expense system should be to reimburse them based on their
total current expenditures for practice costs. Because the higher paid
specialties have more to spend on their practices as a result of
historic charging practices and insurance coverage, there is a concern
that adopting such a methodology would not achieve the desired equity.
The argument made by some outside groups is that physicians have been
increasingly forced to be more efficient and, as a result, differences
in practice expenses among specialties reflect ``real'' costs that
should then be reflected in the new practice expense RVUs.
With the passage of BBA in August 1997, the statute now requires us
to ``utilize, to the maximum extent practicable, generally accepted
cost accounting principles which recognize all staff, equipment,
supplies, and expenses, not just those which can be tied to specific
procedures. * * *'' Therefore, in developing and analyzing any new
alternative methods for computing practice expense RVUs, we have
evaluated how well each option recognizes all practice expense costs.
<bullet> ``Bottom-up'' versus ``Top-down'' Methodology.
In line with our original stated purpose and the 1994 legislation,
our practice expense methodology published in the June 1997 proposed
rule (62 FR 33172) used a ``bottom-up'' approach, which obtained expert
panel estimates of actual inputs--staff times, supplies, and
equipment--for each procedure and then used these estimates to build up
to the direct practice expense RVUs. Some groups complained that some
of the published relative values were too low and favored using studies
that actually measured the inputs onsite. Unfortunately, if any
reliable data exist at all, they are only for a few scattered
specialties, and it certainly is not practical for us to undertake such
a task (Medicare pays physicians for over 7,000 services). We
understand that even the few specialties that have attempted surveys
have had limited success obtaining complete practice expense data from
even limited selected practices.
Many of the specialty societies favored a ``top-down'' methodology,
which would start our calculations with their total current
expenditures and then allocate these costs down to the procedure level
by some method. Several groups supported using an Activity Based
Costing (ABC) methodology for calculating practice expenses. The
proponents of ABC maintain that it produces more accurate costs because
it measures the costs of processes (for example, servicing patients,
scheduling, and billing) as opposed to traditional costing systems,
which measure resources (for example, salaries and rent). However, ABC
is only in the experimental stages in medical practice use, and many
difficult questions about its utility in medical practices have not
been resolved, for example, its assumption that all medical practices
operate in the same manner. ABC still requires subjective estimations,
or some other algorithm, to allocate costs from ``processes'' to
individual CPT codes.
<bullet> Available Data Sources.
Much of the debate about what would constitute the most accurate
practice expense methodology cannot be resolved in the short run. There
is no consensus about the best way to determine the most accurate
practice expense methodology. Furthermore, there are only limited data
sources available. CPEP data, along with the modifications made by our
subsequent panels, are the only source of estimates at the CPT code
level of resource inputs needed to provide each service. AMA's SMS
survey data are from a national survey of randomly selected self-
employed physicians that collects information on practice expense on an
aggregate level, and can be used to determine overall differences in
expenditures among specialties.
The only other relevant data sources of which we are presently
aware are a few other surveys of practice expense, such as those
performed by the MGMA, Medical Economics, and the American College of
Surgeons. Because of selective sampling and low response rates of these
three surveys, these data are not representative of the population of
physicians and cannot be used to derive code-specific RVUs, though the
data might prove useful in validating general impacts.
<bullet> Specialty-Specific Differences.
Our June 1997 proposed rule did not explicitly recognize specialty-
specific differences. Differences across specialties were only
reflected implicitly to the extent that more indirect RVUs would be
allocated to those procedures with the greatest physician work and
direct costs. Under our June 1997 proposed approach, we allocated
indirect relative values based on the typical use of resources, that
is, the direct practice expense RVUs, the physician work RVUs, and the
malpractice RVUs per code.
The specialty groups, along with the AMA and even some primary care
groups, were almost unanimous in their view that we should use an
approach that explicitly recognizes specialty-specific differences in
the indirect cost of practice. It was pointed out, as an example, that
some specialties such as radiology or ophthalmology would have much
higher indirect equipment costs than other specialties. The specialty
groups believed that not recognizing such specialty differences would
be inherently unfair to some specialties. The AMA staff suggested that
we use their survey data to calculate the specialty-specific indirect
costs.
In developing our options for a new practice expense methodology,
we, therefore, needed to decide whether we would maintain specialty-
neutral methods, use specialty differentials to help allocate only
indirect RVUs, or use specialty-specific data to establish the total
redistributive pools for each specialty.
<bullet> Administrative Costs.
Another decision we had to make as we developed new practice
expense RVUs was how a new proposal would treat administrative costs.
The June 1997 proposed rule (62 FR 33167) methodology treated
administrative labor cost as a direct expense, and the administrative
cost RVUs were derived from the CPEP data. On first reviewing the raw
CPEP inputs for administrative staff times, it appeared that there were
some problems with the data. First, some of the suggested
administrative staff times appeared excessively high, particularly for
the billing staff. Second, there was variation in staff times for the
same CPT code between the different panels. In the June 1997 proposed
rule (62 FR 33166), we dealt with these problems through our linking
[[Page 30826]]
methodology and by capping administrative times. Both of these methods
were strongly opposed by many specialty groups, largely because our
adjustments had dramatic effects on the raw data. For example, the
linking coefficient for thoracic surgery reduced their administrative
inputs by 76 percent. There were also comments claiming that many
administrative duties are of a general nature that cannot be fully
captured on a code-specific basis.
As a result of these concerns, many outside groups have suggested
that we treat administrative cost as an indirect practice expense. The
advantages of adopting this suggestion would be that we could get
around the mentioned data discrepancies, avoid the controversial use of
linking for administrative labor, and be more certain that we had
captured all administrative costs. The main disadvantage would be that
it would greatly increase the percentage of RVUs that would have to be
allocated by a formula.
<bullet> Clinical Costs.
Although the problems were on a lesser scale, we observed many of
the same difficulties with the raw CPEP inputs for clinical costs as
there were for the administrative costs discussed above. There was some
lack of standardization of clinical staff types between the CPEP
panels, and some staff times appeared excessive. In the June 1997
proposed rule, these problems were addressed by linking and by capping
the clinical times; both of these methods caused considerable
controversy in the medical community. We had hoped that the validation
and cross-specialty panels would have resolved the inconsistencies
across specialties, but they were unable to accomplish this task. It
was clear, therefore, that any new proposal would still have to address
a method of standardizing the data between the various specialty
panels.
<bullet> The General Accounting Office (GAO) Report to Congress on
Physician Practice Expense.
As already mentioned, BBA 1997 required the GAO to review and
evaluate our June 1997 proposed rule on a resource-based methodology
for practice expenses. This report was issued in February 1998 and
concluded that both our use of expert panels to develop direct cost
estimates and our original allocation methodology for indirect costs
were acceptable options. However, the GAO raised questions about the
validity of some specifics of the linking regression model and about
the appropriateness of capping administrative and clinical labor time
estimates. In addition, the report suggested that using specialty-
specific indirect expense ratios, based on the SMS survey data, would
be more clearly consistent with BBA 1997. Also, the report recommended
that we consider classifying administrative labor costs as indirect
expenses. (See section 18 for a more detailed discussion of the
report's recommendations.)
9. Alternative Practice Expense Methodologies Considered
We carefully considered two alternative approaches to developing
new practice expense RVUs: the first maintained the ``bottom-up''
methodology of our original proposal, while the second adopted a ``top-
down'' methodology.
<bullet> ``Bottom-up'' Option.
We regard our original ``bottom-up'' proposal as a viable method of
developing practice expense RVUs. It clearly fulfilled the requirement
of the Social Security Amendments of 1994, which states that practice
expense relative values should be based on the relative practice
expense resources involved in furnishing the service. Both the GAO and
the Physician Payment Review Commission, as well as many researchers in
the field, supported our use of expert panels to estimate direct
practice expenses. Therefore, we developed a method that was similar to
our original proposal.
Like our proposal in the June 1997 proposed rule, this option based
its calculation for all direct inputs on the data reported by the
CPEPs. As before, both clinical and administrative labor were linked,
and all direct cost estimates were scaled as in the original proposed
rule. However, in a significant departure from our original proposal,
the caps on clinical and administrative staff times were eliminated.
For indirect costs, this option continued not to recognize a specialty-
specific method of cost allocation to specific procedures. It did,
however, have a different indirect allocation formula from our original
proposal; under this option, 50 percent would be allocated on the basis
of direct costs and 50 percent on the basis of physician time. Of the
latter 50 percent, physician time in the office would get a weight 50
percent higher than physician time out of the office. If there was no
physician involvement, as is the case with technical component
services, the maximum clinical staff time would be used.
<bullet> The ``Top-Down'' Option.
This option is a departure from our original proposal and is an
effort to balance the requirements of the 1994 Social Security
Amendments with the 1997 BBA requirements. It uses the two significant
sources of actual practice expense data we have available: the CPEP
data and the AMA's SMS survey data. It allocates current aggregate
specialty practice costs to specific procedures and, thus, can be seen
as a ``top-down'' approach.
This option is based on an assumption that current aggregate
specialty practice costs are a reasonable way to establish initial
estimates of relative resource costs of physician services across
specialties. The specialty practice cost data are derived from the
AMA's SMS survey data on actual practice expenses. The survey data are
used to calculate the practice expenses generated for every hour worked
by a physician. The average practice expense per hour for the
physicians in a given specialty is then multiplied by the total number
of physician hours worked by that specialty as reflected in the
Medicare claims data. This determines the total pool of practice
expense payments for that specialty. We then allocated this pool to the
procedures performed by that specialty using the CPEP data (excluding
the administrative staff time associated with specific procedures) and
the physician work RVUs. We calculated a weighted average of the
practice expense payments for procedures performed by more than one
specialty.
After much analysis and discussion, we have decided to propose the
``top-down'' methodology. We believe the ``top-down'' methodology is
more responsive than the ``bottom-up'' approach to both BBA 1997
requirements and to many of the concerns of the medical community. By
using aggregate specialty practice costs as the basis for establishing
the practice expense pools, we are recognizing all of a specialty's
costs, not just those linked with a specific procedure. By basing the
redistributions of the practice expense system on physician-reported
actual practice expense data, by using a specialty-specific allocation
method, and by treating administrative costs as an indirect expense, we
avoid many of the criticisms leveled at our original proposal.
We also believe this option is responsive to the short-term
recommendations in the GAO Report to Congress on physician practice
expense payments relating to the June 1997 proposed rule's limits on
clinical and administrative staff time and possible changes in the
linking algorithm. Our recommended methodology would make these
recommendations moot by eliminating the limits and linking algorithm
that were part of our previous
[[Page 30827]]
proposal. Finally, based on our experiences with the validation panels
we held in October and December 1997, we believe the ``top-down''
approach will be less difficult to refine.
10. Description of the Proposed Methodology for Developing Practice
Expense Relative Value Units
(See Addendum B for a detailed technical description of the proposed
methodology.)
a. Overview. We used actual practice expense data by specialty to
create six cost pools (administrative labor, clinical labor, medical
supplies, medical equipment, office supplies, and all other). We then
allocated these cost pools to individual procedure codes. An overview
of this approach is presented in Exhibit 1.
Exhibit 1. Overall Allocation Approach
[GRAPHIC] [TIFF OMITTED] TP05JN98.019
b. Data Sources. We used the 1995 through 1997 AMA's SMS survey
data to develop the cost pools and the CPEP data to allocate these cost
pools to procedure codes.
The AMA originally developed the SMS in 1981. It covers a broad
range of economic and practice characteristics. The annual SMS survey
is designed to provide representative information on the population of
all non-federal physicians who spend the greatest proportion of their
time in patient care activities. The survey is sent to both office and
hospital-based physicians, but excludes residents. The recipients of
the survey are randomly selected from the AMA's physician master file,
which contains current and historical information on every physician in
the United States, including nonmembers of the AMA.
The SMS survey consists of three distinct sections:
<bullet> Screening questions to verify the physician's self-
designated practice specialty and eligibility for the survey.
<bullet> A main questionnaire to collect information on practice
characteristics, hours worked, volume of services, fees for selected
procedures, income, and expenses.
<bullet> Special topic questions to provide information on key
socioeconomic issues.
The SMS survey is a computer-assisted telephone survey that checks
the consistency of responses during the survey and automatically skips
questions that are not relevant to the physician. To prepare the
physician, the AMA mails a practice expense summary in advance. The
physician may designate a proxy such as a practice manager or an
accountant to answer the practice expense questions. The AMA makes
vigorous efforts to achieve a high response rate despite the short
field period of surveys. Each interviewer's work is monitored by
supervisory staff for both production and quality. AMA staff also
monitors interviews to ensure that a high level of quality is
maintained throughout the survey.
The CPEP data were collected from panels of physicians, practice
administrators, and nonphysicians (for example, registered nurses) who
were nominated by physician specialty societies and other groups. There
were 15 CPEPs consisting of 180 members from more than 61 specialties
and subspecialties. Approximately 50 percent of the panelists were
physicians. The CPEPs identified the direct inputs involved in each
physician service for procedure codes in an office setting and out-of-
office setting. (See Addendum A for a detailed description of the CPEP
process.)
c. Practice Expense Cost Pools. We created practice expense cost
pools by physician specialty for clinical labor, administrative labor,
medical supplies, medical equipment, office supplies, and all other
expenses. There are three steps in the creation of the cost pools.
Step 1: Use the AMA's SMS survey data of actual cost data, by
physician specialty, for 1995 through 1997 to determine practice
expenses per hour by cost category.
Step 2: Determine the total number of physician hours, by
specialty, spent treating Medicare patients as reflected in the
Medicare claims data.
Step 3: Calculate the practice expense pools by specialty and by
cost category using the results from step 1 and step 2.
A short description of each step follows.
Step 1: Determine practice expenses per hour by cost category.
Based on the AMA's SMS survey data for each physician respondent,
we calculated practice expenses per hour spent in patient care
activities by cost pool. We made the following assumptions in this
calculation:
<bullet> The physician respondent shares practice expense equally
with all other physician owners in the practice.
<bullet> The physician respondent works the same number of hours as
all other physician owners in the practice.
<bullet> For any employee physician in the practice, the hours
spent in patient care activities are the average hours spent in patient
care activities for employee physicians in the specialty of the
physician respondent.
Using the above assumptions, the practice expenses per hour for
each physician respondent's practice was calculated as the practice
expenses for the practice divided by the total number
[[Page 30828]]
of hours spent in patient care activities by the physicians in the
practice. The practice expenses per hour for the specialty are an
average of the practice expenses per hour for the respondent physicians
in that specialty.
Step 2: Determine the number of physician hours spent treating
Medicare patients.
For each specialty, the total number of physician hours spent
treating Medicare patients was calculated from physician time data for
each procedure code and the Medicare claims data. The primary sources
for the physician time data are surveys submitted to the AMA's RUC and
surveys done by Harvard for the initial establishment of the work RVUs.
Step 3: Determine the practice expense pools by specialty and by
cost category.
The practice expense cost pools for clinical labor, administrative
labor, medical supplies, medical equipment, office expenses, and all
other expenses are determined by multiplying the practice expenses per
hour for these categories (calculated in step 1) by the total physician
hours (calculated in step 2).
d. Cost Allocation Methodology
We allocated by specialty each practice expense cost pool to
individual procedure codes either using the CPEP data for clinical
labor, medical supplies, and medical equipment, or using a combination
of the CPEP data for clinical labor, medical supplies, and medical
equipment and the physician fee schedule work RVUs.
Exhibit 2 depicts our cost allocation methodology. For each
specialty, the six cost pools and their respective cost allocation
bases are used to determine costs for each procedure code.
Exhibit 2. Cost Allocation Methodology
[GRAPHIC] [TIFF OMITTED] TP05JN98.020
Step 4: Allocate the practice expense pools by specialty to
individual procedures.
For each specialty, we separated the six practice expense pools
(clinical labor, administrative labor, medical supplies, medical
equipment, office expenses, and all other expenses) created in Step 3
into two groups and used a different allocation basis for each group.
Group one includes clinical labor, medical supplies, and medical
equipment, and group two includes administrative labor, office
expenses, and all other expenses.
Group one: clinical labor, medical supplies, and medical equipment.
We used the CPEP data as the allocation basis for the group one
pools (clinical labor, medical supplies, and medical equipment). The
CPEP data for clinical labor were used to allocate the clinical labor
cost pool, the CPEP data for medical supplies were used to allocate the
medical supplies cost pool, and the CPEP data for medical equipment
were used to allocate the medical equipment cost pool.
Group two: administrative, labor, office expenses, and other
expenses.
For the allocation of administrative labor, office expenses, and
other expenses, a combination of the group one cost allocations and the
physician fee schedule work RVUs was used to allocate the cost pools.
Step 5: Weight average allocations for procedures performed by more
than one specialty.
For procedures performed by more than one specialty, the final
procedure code allocation was a weighted average of allocations for the
specialties that perform the procedure, with the weights being the
frequency with which each specialty performs the procedure on Medicare
patients.
11. Comments of the American Medical Association Regarding the Use of
the Socioeconomic Monitoring System Survey Data to Construct Practice
Expense Relative Value Units
At our request, the AMA sent two tables summarizing practice
expense information by physician specialty. Additionally, the AMA
supplied us with SMS background information and comments regarding its
use to construct resource-based practice expense RVUs.
The following are the AMA's comments as well as two tables derived
from the SMS data:
The SMS survey is an annual nationally representative survey of
physicians drawn randomly from the AMA's Physician Masterfile (a
listing of all member and nonmember physicians in the United
States). The survey was conducted by an external contractor--the
Rand Corporation was the survey contractor for the 1995 through 1997
SMS surveys. Unit response rates to SMS have been roughly 60 percent
in recent years, which is as high or higher than comparable
physician surveys. It is a computer-assisted telephone survey which
allows checks to be made for the consistency of responses during the
survey and to automatically skip questions that are not relevant to
particular physicians. On the practice expense questions, special
effort is made to obtain accurate information. A practice expense
summary is mailed to all physicians that are to be surveyed to allow
them to obtain the information before being contacted. The physician
may designate a proxy such as a
[[Page 30829]]
practice manager or accountant to answer the practice expense
questions if they do not have the information.
However, it is important to stress that the SMS data were never
collected for the purpose of developing relative values. We feel
that there are several potential problems with using SMS data to
construct practice expense RVUs. These concerns were first raised in
a letter from the AMA to HCFA in November 1996. In particular, we
are concerned that:
--Sample sizes for some specialties will be too small to permit
separate calculation of expense data from SMS. Even among the larger
specialties, the inherent variability of the expense data will mean
that the average expense figures provided will be subject to
significant sampling error.
--Response rates for the expense items tend to be low relative to
other questions on the survey leading to potential non-response
bias.
--SMS is a physician-level survey, and physicians in groups are
asked for their share of expenses rather than the practice's
expenses. Practice-level data may provide a better basis for
constructing practice expense RVUs.
Despite these problems, we recognize your need to use the best
available information. The tables that you requested show the means
and standard errors of practice expenses per direct patient care
hour from the 1995 through 1997 SMS surveys. Since SMS collects
practice expense data for the prior year, these tables summarize SMS
respondents' hourly expenses for the years 1994 through 1996. Only
non-federal, non-resident, patient care physicians are surveyed on
SMS. In addition, only physicians who are full or part-owners of
their practices are asked the practice expense questions. The
following records were excluded prior to tabulating the data as you
requested:
--Physicians practicing fewer than 26 weeks the prior year
(including cases where weeks worked the previous year were missing);
--Cases with a missing response to the question on typical hours in
direct patient care per week (3 cases where the response to this
question was 168 hours were also excluded);
--Cases where any of the individual expense items (total non-
physician personnel expense; clerical non-physician personnel
expense; office expenses; medical supplies expenses; medical
equipment expenses; and other or miscellaneous practice expenses)
were missing; and
--Cases where total expenses (excluding professional liability
insurance premiums and employee physician payroll expense) were
zero.
Expenses per hour were calculated as you requested (and as
described in the notes to the tables). All results were weighted for
unit non-response. It will not be possible to replicate these
figures exactly from the AMA's Physician Marketplace Statistics or
Socioeconomic Characteristics of Medical Practice publications due,
in part, to the exclusions mentioned above.
[[Page 30830]]
Table 1.--Mean Practice Expenses Per Hour Spent in Patient Care Activities, Hours and Expenses Adjusted for Practice Size
[In dollars]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Non-phys Clerical Office Supplies Equipment Other Total
Specialty Number of payroll per payroll per expense per expense per expense per expense per expense per
cases hour hour* hour hour hour hour hour**
--------------------------------------------------------------------------------------------------------------------------------------------------------
ALL PHYSICIANS.................................. 3910 27.0 15.0 19.1 7.2 3.2 11.0 67.5
GENERAL/FAMILY PRACTICE......................... 409 30.2 15.1 18.2 8.1 3.6 8.6 68.6
GENERAL INTERNAL MEDICINE....................... 430 22.4 13.3 17.0 6.4 2.1 6.2 54.2
CARDIOVASCULAR DISEASE.......................... 94 30.2 14.9 19.9 5.8 6.4 20.7 82.9
GASTROENTEROLOGY................................ 84 23.2 15.4 17.9 2.7 1.8 11.0 56.6
ALLERGY/IMMUNOLOGY.............................. 31 66.2 27.0 33.3 17.5 3.3 16.4 136.6
PULMONARY DISEASE............................... 49 20.0 12.2 15.0 2.8 1.6 6.4 45.8
ONCOLOGY........................................ 27 44.7 22.7 25.7 87.2 5.5 10.3 173.4
GENERAL SURGERY................................. 257 22.5 15.7 17.2 3.1 2.0 9.4 54.1
OTOLARYNGOLOGY.................................. 103 44.8 27.3 33.4 7.7 5.8 18.3 110.1
ORTHOPEDIC SURGERY.............................. 203 42.9 26.0 30.8 10.3 3.6 18.1 105.6
OPHTHALMOLOGY................................... 210 52.9 27.8 35.9 11.3 9.0 22.7 131.8
UROLOGICAL SURGERY.............................. 118 29.6 18.6 22.8 24.5 6.0 11.6 94.6
PLASTIC SURGERY................................. 85 28.6 18.3 30.2 16.3 4.6 23.3 103.0
NEUROLOGICAL SURGERY............................ 42 33.5 24.3 31.7 1.8 1.1 15.7 83.9
CARD/THOR/VASC SURGERY.......................... 44 30.1 16.2 18.3 1.4 3.1 11.0 63.8
PEDIATRICS...................................... 249 26.1 13.3 20.0 10.8 1.6 8.4 66.9
OBSTETRICS/GYNECOLOGY........................... 266 32.3 16.9 21.2 7.3 3.4 11.7 75.9
RADIOLOGY....................................... 214 19.0 9.6 12.5 4.8 8.3 13.6 58.2
PSYCHIATRY...................................... 351 7.3 5.3 10.1 0.4 0.3 7.5 25.6
ANESTHESIOLOGY.................................. 232 14.4 3.7 5.9 0.3 0.4 5.7 26.7
PATHOLOGY....................................... 82 16.7 8.4 6.7 4.0 1.6 17.7 46.7
DERMATOLOGY..................................... 96 49.5 26.7 33.1 12.5 4.8 15.2 115.0
EMERGENCY MEDICINE.............................. 61 5.3 1.9 1.6 0.5 0.1 5.5 13.0
NEUROLOGY....................................... 61 26.2 21.6 15.8 5.0 4.2 7.7 58.8
PHYS MED/RHEUMATOLOGY........................... 75 38.6 23.2 28.5 4.9 3.9 12.0 88.0
OTHER SPECIALTY................................. 37 21.1 12.4 19.7 3.6 1.3 9.7 55.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Source: American Medical Association, 1995-1997 Socioeconomic Monitoring System (SMS) surveys.
* Clerical payroll is included in total non-physician payroll.
** Total expenses exclude professional liability insurance premiums and employee physician payroll.
Notes:
(1) Only self-employed non-federal non-resident patient care physicians who responded to all relevant expense questions are included.
Self-employed physician respondents with no practice expenses for the year are excluded.
(2) Physicians whose typical number of hours worked in patient care activities per week is missing, less than 20, or equal to 168 (3 cases) are
excluded. Physicians whose number of weeks worked the previous year is missing or less than 26 are excluded.
(3) For each respondent, total practice expense and expense components per hour are calculated as (4)/(5) below.
(4) Expenses adjusted for practice size = self-employed respondent expenses* # physician owners.
(5) Hours adjusted for practice size = (respondent hours* # physician owners) + (employee physician hours (see (6) below)* # employee physicians).
6) The typical number of hours worked in patient care activities for the employee physician(s) of a self-employed physician's practice is not known.
Mean hours worked in patient care activities for employee physicians of each specialty are used as an estimate of employee physician hours.
[[Page 30831]]
Table 2.--Standard Errors of Mean Practice Expenses per Hour Spent in Patient Care Activities, Hours and Expenses Adjusted for Practice Size
[In dollars]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Non-phys Clerical Office Supplies Equipment Other Total
Specialty Number of payroll per payroll per expense per expense per expense per expense per expenses
cases hour hour hour hour hour hour per hour **
--------------------------------------------------------------------------------------------------------------------------------------------------------
ALL PHYSICIANS.................................. 3910 0.5 0.3 0.4 0.3 0.2 0.3 1.1
GENERAL/FAMILY PRACTICE......................... 409 1.3 0.6 1.2 0.5 0.7 0.6 3.0
GENERAL INTERNAL MEDICINE....................... 430 1.2 0.6 1.0 0.6 0.3 0.6 2.6
CARDIOVASCULAR DISEASE.......................... 94 2.9 1.4 1.9 0.8 1.3 5.2 8.0
GASTROENTEROLOGY................................ 84 1.6 1.1 1.9 0.3 0.3 2.2 4.1
ALLERGY/IMMUNOLOGY.............................. 31 7.9 3.8 3.8 4.2 1.5 2.9 11.2
PULMONARY DISEASE............................... 49 1.6 1.4 2.2 0.6 0.5 0.9 3.5
ONCOLOGY........................................ 27 7.5 3.8 5.7 16.4 1.4 3.8 23.2
GENERAL SURGERY................................. 257 1.4 0.9 0.9 0.3 0.3 0.8 2.5
OTOLARYNGOLOGY.................................. 103 3.0 2.3 3.5 0.9 1.1 2.1 6.8
ORTHOPEDIC SURGERY.............................. 203 1.7 1.2 2.1 0.8 0.4 2.0 4.7
OPHTHALMOLOGY................................... 210 2.9 1.4 2.6 1.3 1.1 2.1 6.3
UROLOGICAL SURGERY.............................. 118 1.4 1.0 2.1 1.8 1.0 1.4 4.4
PLASTIC SURGERY................................. 85 2.3 1.4 3.5 2.8 1.0 3.4 8.1
NEUROLOGICAL SURGERY............................ 42 4.0 2.5 5.7 0.7 0.4 2.1 9.4
CARD/THOR/VASC SURGERY.......................... 44 4.2 2.0 2.9 0.3 1.7 2.2 8.0
PEDIATRICS...................................... 249 1.6 0.7 1.7 1.0 0.3 1.2 3.8
OBSTETRICS/GYNECOLOGY........................... 266 1.7 0.9 1.3 0.7 0.3 1.0 3.3
RADIOLOGY....................................... 214 2.0 0.9 2.0 0.8 1.9 1.3 5.7
PSYCHIATRY...................................... 351 0.7 0.5 0.6 0.2 0.1 0.6 1.5
ANESTHESIOLOGY.................................. 232 1.8 0.6 0.8 0.1 0.1 0.7 2.4
PATHOLOGY....................................... 82 2.7 1.8 1.7 0.8 0.5 2.9 6.4
DERMATOLOGY..................................... 96 4.8 2.0 5.2 2.0 1.2 1.8 10.4
EMERGENCY MEDICINE.............................. 61 1.4 0.6 0.5 0.3 0.1 0.9 2.1
NEUROLOGY....................................... 61 3.1 3.1 1.4 1.5 1.1 2.2 6.4
PHYS MED/RHEUMATOLOGY........................... 75 5.1 2.5 6.1 0.7 1.4 2.9 12.1
OTHER SPECIALTY................................. 37 4.4 2.4 5.1 1.1 0.6 2.1 9.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Source: American Medical Association, 1995-1997 Socioeconomic Monitoring System (SMS) surveys.
* Clerical payroll is included in total non-physician payroll.
** Total expenses exclude professional liability insurance premiums and employee physician payroll.
Notes:
(1) Only self-employed non-federal non-resident patient care physicians who responded to all relevant expense questions are included. Self-employed
physician respondents with no practice expenses for the year are excluded.
(2) Physicians whose typical number of hours worked in patient care activities per week is missing, less than 20, or equal to 168 (3 cases) are
excluded. Physicians whose number of weeks worked the previous year is missing or less than 26 are excluded.
(3) For each respondent, total practice expense and expense components per hour are calculated as (4)/(5) below.
(4) Expenses adjusted for practice size = self-employed respondent expenses * # physician owners.
(5) Hours adjusted for practice size = (respondent hours * # physician owners) + (employee physician hours (see (6) below) * # employee physicians).
(6) The typical number of hours worked in patient care activities for the employee physician(s) of a self-employed physician's practice is not known.
Mean hours worked in patient care activities for employee physicians of each specialty are used as an estimate of employee physician hours.
12. Other Methodological Issues
a. Professional and Technical Component Services. Using the
methodology described above, the professional and technical components
of the resource-based practice expense relative value units do not
necessarily sum to the global resource-based practice expense relative
value units since specialties with different practice expenses per hour
provide the components of these services in different proportions. For
example, emergency medicine physicians have proportionately more
professional component chest x-ray billings than global billings
relative to radiologists. We used the following methodologies so that
the professional and technical component resource-based practice
expense relative value units for a service sum to the global resource-
based relative value units.
For codes with professional and technical components excluding
HCPCS codes 70010 through 79440, G0030 through G0047, G0050, G0062,
G0063, G0106, G0120, G0122, G0125, and G0126, we used the following
methodology:
After we determined the practice expense RVUs using the practice
expense per hour methodology, we budget neutrally distributed the total
(global, professional, and technical) practice expense payments for
each code between the global, professional, and technical components as
follows:
Step 1: Calculate a weighted average resource-based practice
expense RVU across the facility and nonfacility settings using the
allowed utilization from the Medicare claims data.
Step 2: Using the RVUs calculated in Step 1 for the global,
professional, and
[[Page 30832]]
technical components of each code and the Medicare utilization data,
calculate the total new resource-based practice expense payments for
each code.
Step 3: Set the global resource-based practice expense RVUs for
each code equal to the sum of the resource-based practice expense RVUs
for the professional and technical components calculated in Step 2.
Step 4: Using the global RVUs calculated in Step 3, the
professional and technical component RVUs calculated in Step 1, and the
Medicare utilization data, calculate practice expense payments for each
code.
Step 5: Multiply the global relative value units calculated in Step
3 and the professional and technical component RVUs calculated in Step
1 by the ratio of the practice expense payments for each code
calculated in Step 2 to the practice expense payments for each code
calculated in Step 4.
For HCPCS codes 70010 through 79440, G0030 through G0047, G0050,
G0062, G0063, G0106, G0120, G0122, G0125, and G0126, we used the
following methodology:
We used the current 1998 practice expense RVUs for this set of
codes, which are based primarily on the original radiology fee
schedule, to determine the relatives between the new resource-based
practice expense relative value units as follows:
Step 1: Using the current 1998 practice expense RVUs, calculate the
current aggregate practice expense payments for this set of codes.
Step 2: Using the resource-based practice expense RVUs determined
from the methodology described above, calculate the aggregate practice
expense payments for this set of codes.
Step 3: Uniformly multiply the current practice expense RVUs by the
ratio of the aggregate resource-based practice expense payments
calculated in Step 2 to the aggregate practice expense payments
calculated in Step 1.
For HCPCS codes Q0092, R0070, and R0075, we used the following
methodology:
The practice expense RVUs for HCPCS code Q0092 was determined by
applying the ratio described in Step 3 above to the existing practice
expense RVUs. The practice expense RVUs for HCPCS codes R0070 and R0075
were determined by applying the ratio described above to practice
expense RVUs for these codes calculated from the average allowed charge
in the Medicare claims data.
b. Practice Expenses per Hour Adjustments and Specialty Crosswalks.
We have one general comment on our use of the SMS practice expense per
hour data. Some practices employ midlevel providers such as nurse
practitioners and optometrists. The practice expenses per hour from the
SMS survey are calculated in terms of hours spent in patient care
activities by physicians in a practice. These practice expenses per
hour are greater than practice expenses per hour spent in patient care
activities by the physicians and midlevel providers in a practice. As a
result, the practice expense per hour methodology is potentially biased
in favor of specialties who use more, relative to other specialties,
midlevel providers as physician extenders to create billable services
under the Medicare fee schedule. Although we made no adjustment to the
practice expenses per hour for this due to a lack of data, we believe
the issue should be examined as part of the refinement of the resource-
based practice expense RVUs.
Below are the adjustments we made to the practice expense per hour
data and the crosswalks we used to assign the specialties reflected in
our claims data to those found in the practice expense tables from the
SMS survey data.
<bullet> We set the medical materials and supplies practice
expenses per hour for the specialties of ``Oncology'' and ``Allergy and
Immunology'' equal to the medical materials and supplies practice
expenses per hour for ``All Physicians'' since we make separate payment
for the drugs furnished by these specialties.
With regard to oncology, while Medicare does not have an expansive
outpatient drug benefit, it does cover outpatient drugs that are
furnished by a physician, oral cancer drugs, and certain other specific
drugs. In addition to paying for the costs of these drugs (outside the
physician fee schedule), Medicare also makes a separate payment to
physicians for the ``administration'' of cancer drugs (under the
physician fee schedule). This separate payment for chemotherapy
administration recognizes the expenses involved with ordering, storing
and handling, and performing other tasks associated with administering
such drugs. These expenses are practice expenses and are treated as
part of resource-based practice expenses; they are not part of the
costs of the drug and are not included in Medicare payments for
chemotherapy drugs.
We believe that physicians' expenses for the administration of
cancer drugs, as well as the costs of the drugs themselves, are
included in their responses to the AMA survey. Therefore, to avoid a
duplicate payment (that is, paying for the drug separately and also
including the costs of the drug in practice expenses), we need to
separate the costs of the drug from the practice expenses for the
administration of the chemotherapy drugs.
We are proposing to use the ``All Physician'' practice expenses per
hour for medical materials and supplies to reflect, in a relative
sense, all the practice expenses for administration of chemotherapy.
The difference between the practice expense per hour for medical
material and supplies for oncologists and for all physicians would be
the costs of the drugs themselves. We invite comments about our
approach or alternative ways to separate the costs of the drugs from
the costs of their administration.
<bullet> We based the administrative payroll, office, and other
practice expenses per hour for the specialties of ``Physical Therapy''
and ``Occupational Therapy'' on data used to develop the salary
equivalency guidelines for these specialties. (Since speech and
language pathologists are not identified as Medicare specialties in our
claims data, we could not explicitly use their salary equivalency
guideline data.) The data used to calculate the salary equivalency
practice expenses per hour for these categories of expenses includes an
allowance for 250 square feet of space per therapist, and the utilities
and other overhead to run the practice, including administrative costs.
We set the remaining practice expense per hour categories equal to the
``All Physicians'' practice expenses per hour from the SMS survey data.
We used the clinical payroll expenses for ``All Physicians'' instead of
the salary equivalency data for physical therapy assistants and aides
since we are concerned that there may be an overlap between the cost of
therapy assistants and aides reflected in the practice expenses and the
amount of work allocated to services provided by occupational and
physical therapists.
<bullet> The following are the crosswalks we used to assign the
specialties reflected in our claims data to those found in the practice
expense tables from the SMS survey data. Note that we refer to the
difference between the nonphysician payroll expenses per hour and the
clerical payroll expenses per hour as the clinical payroll expenses per
hour.
[[Page 30833]]
Table 3.--Practice Expense per Hour Crosswalks
----------------------------------------------------------------------------------------------------------------
Medical Medical Cler.,
HCFA specialty code and AMA specialty Clinical supplies PE/ equipment office, and
description labor PE/Hr Hr PE/Hr other PE/Hr
----------------------------------------------------------------------------------------------------------------
01--General Practice............. General/Family Practice.. $15.10 $8.10 $3.60 $41.90
02--General Surgery.............. General Surgery.......... 6.80 3.10 2.00 42.30
03--Allergy/Immunology........... Allergy And Immunology*.. 39.20 7.20 3.30 76.70
04--Otology, Laryn., Rhino....... Otolaryngology........... 17.50 7.70 5.80 79.00
05--Anesthesiology............... Anesthesiology........... 10.70 0.30 0.40 15.30
06--Cardiology................... Cardiovascular Disease... 15.30 5.80 6.40 55.50
07--Dermatology.................. Dermatology.............. 22.80 12.50 4.80 75.00
08--Family Practice.............. General/Family Practice.. 15.10 8.10 3.60 41.90
10--Gastroenterology............. Gastroenterology......... 7.80 2.70 1.80 44.30
11--Internal Medicine............ General Internal Medicine 9.10 6.40 2.10 36.50
12--Manip. Therapy............... All Physicians........... 12.00 7.20 3.20 45.10
13--Neurology.................... Neurology................ 4.60 5.00 4.20 45.10
14--Neurosurgery................. Neurological Surgery..... 9.20 1.80 1.10 71.70
16--OB-GYN....................... Obstetrics/Gynecology.... 15.40 7.30 3.40 49.80
18--Ophthalmology................ Ophthalmology............ 25.10 11.30 9.00 86.40
19--Oral Surgery................. All Physicians........... 12.00 7.20 3.20 45.10
20--Orthopedic Surgery........... Orthopedic Surgery....... 16.90 10.30 3.60 74.90
22--Pathology.................... Pathology................ 8.30 4.00 1.60 32.80
24--Plastic Surgery.............. Plastic Surgery.......... 10.30 16.30 4.60 71.80
25--Physical Medicine............ Physical Medicine/ 15.40 4.90 3.90 63.70
Rheumatology.
26--Psychiatry................... Psychiatry............... 2.00 0.40 0.30 22.90
28--Colorectal Surgery........... General Surgery.......... 6.80 3.10 2.00 42.30
29--Pulmonary Disease............ Pulmonary Disease........ 7.80 2.80 1.60 33.60
30--Radiology.................... Radiology................ 9.40 4.80 8.30 35.70
33--Thoracic Surgery............. Cardiac/Thoracic/Vascular 13.90 1.40 3.10 45.50
Surgery.
34--Urology...................... Urological Surgery....... 11.00 24.50 6.00 53.00
35--Chiropractor, Licensed....... General Internal Medicine 9.10 6.40 2.10 36.50
36--Nuclear Medicine............. Radiology................ 9.40 4.80 8.30 35.70
37--Pediatrics................... Pediatrics............... 12.80 10.80 1.60 41.70
38--Geriatrics................... General Internal Medicine 9.10 6.40 2.10 36.50
39--Nephrology................... General Internal Medicine 9.10 6.40 2.10 36.50
40--Hand Surgery................. Orthopedic Surgery....... 16.90 10.30 3.60 74.90
41--Optometrist.................. All Physicians........... 12.00 7.20 3.20 45.10
43--CRNA/AA...................... Anesthesiology........... 10.70 0.30 0.40 15.30
44--Infectious Disease........... General Internal Medicine 9.10 6.40 2.10 36.50
46--Endocrinology................ General Internal Medicine 9.10 6.40 2.10 36.50
48--Podiatry..................... General Surgery.......... 6.80 3.10 2.00 42.30
50--Nurse Practitioners.......... General Internal Medicine 9.10 6.40 2.10 36.50
62--Psychologist (Billing Psychiatry............... 2.00 0.40 0.30 22.90
Independently).
65--Physical Therapist (Indep. All Physicians*.......... 12.00 7.20 3.20 10.90
Practice).
66--Rheumatology................. Physical Medicine/ 15.40 4.90 3.90 63.70
Rheumatology.
67--Occupational Therapist....... All Physicians*.......... 12.00 7.20 3.20 10.90
68--Clinical Psychologist........ Psychiatry............... 2.00 0.40 0.30 22.90
69--Independent Laboratory....... All Physicians........... 12.00 7.20 3.20 45.10
70--Clinic Or Other Group........ All Physicians........... 12.00 7.20 3.20 45.10
76--Periperal Vascular Disease... All Physicians........... 12.00 7.20 3.20 45.10
77--Vascular Surgery............. Cardiac/Thoracic/Vascular 13.90 1.40 3.10 45.50
Surgery.
78--Cardiac Surgery.............. Cardiac/Thoracic/Vascular 13.90 1.40 3.10 45.50
Surgery.
79--Addiction Medicine........... Psychiatry............... 2.00 0.40 0.30 22.90
80--Clinical Social Worker....... Psychiatry............... 2.00 0.40 0.30 22.90
81--Critical Care (Intensivists). All Physicians........... 12.00 7.20 3.20 45.10
82--Hematology................... General Internal Medicine 9.10 6.40 2.10 36.50
83--Hematology/Oncology.......... Oncology*................ 22.00 7.20 5.50 58.70
84--Preventive Medicine.......... General Internal Medicine 9.10 6.40 2.10 36.50
85--Maxillofacial Surgery........ All Physicians........... 12.00 7.20 3.20 45.10
86--Neuropsychiatry.............. Psychiatry............... 2.00 0.40 0.30 22.90
89--Clinical Nurse Practitioner.. General Internal Medicine 9.10 6.40 2.10 36.50
90--Medical Oncology............. Oncology................. 22.00 7.20 5.50 58.70
91--Surgical Oncology............ All Physicians........... 12.00 7.20 3.20 45.10
92--Radiation Oncology........... Radiology................ 9.40 4.80 8.30 35.70
93--Emergency Medicine........... Emergency Medicine....... 3.40 0.50 0.10 9.00
94--Interventional Radiology..... Radiology................ 9.40 4.80 8.30 35.70
95--Indep. Physiological Lab..... All Physicians........... 12.00 7.20 3.20 45.10
97--Physician Assistants......... General/Family Practice.. 15.10 8.10 3.60 41.90
98--Gynecology/Oncology.......... Obstetrics/Gynecology.... 15.40 7.30 3.40 49.80
----------------------------------------------------------------------------------------------------------------
* Practice expense per hour were adjusted as follows:
(1) Allergy & Immunology and Oncology use supplies for All Physicians.
(2) Physical Therapy and Occupational Therapy use salary equivalency data for clerical, office and other
practice expenses per hour.
[[Page 30834]]
<bullet> Due to uncertainty concerning the appropriate crosswalk
and time data for the nonphysician specialty ``Audiologist'' and the
fact that the relatively few codes performed by audiologists are also
performed by other specialties, we did not crosswalk this specialty.
Until we can obtain more data, we derived the resource-based practice
expense RVUs for codes performed by audiologists from the practice
expenses per hour of the other specialties which perform these codes.
<bullet> Because we have no reason to assume that the distribution
of radiologists by equipment ownership reflected in the SMS survey data
differs from the distribution found in our claims data, we did not
attempt to differentiate the practice expenses per hour for
radiologists by equipment ownership. The use of the average practice
expenses per hour should create the appropriate practice expense pool
for radiology. We invite comments on this issue. We realize that
practice expenses vary by equipment ownership; however, the appropriate
recognition of this is through the differential allocation of the
practice expense pool to the professional, technical, and global
services performed by radiologists.
c. Time Associated with the Work Relative Value Units. As a
general comment on the time data, we are concerned that any imprecision
in the time estimates for high volume services which have relatively
little time associated with them may potentially bias the practice
expense methodology in favor of the specialties which perform these
services. For example, if a high volume procedure which typically takes
four minutes to perform has a surveyed time of 5 minutes, this
procedure's contribution to the practice expense pool for that
specialty is inflated by 25 percent. In contrast, if a procedure which
typically takes 100 minutes to perform has a surveyed time of 101
minutes, its contribution is only inflated by 1 percent. We believe
this issue should be examined as part of the refinement of the
resource-based practice expense RVUs.
<bullet> The time data from the Harvard study performed for the
initial establishment of the work relative value units were collected
over a number of years using primarily surveys of practicing
physicians. The time data submitted to the RUC for the refinement of
the work relative value units were also collected over a number of
years using primarily physician surveys. The time data resulting from
the refinement of the work relative value units have been
systematically greater than the time data obtained by the Harvard study
for the same services. On average, this difference is approximately 25
percent. We increased the Harvard time data in order to ensure
consistency between these data sources.
<bullet> We calculated the total physician time for CPT codes 70010
through 79440 using the work RVUs and the work per unit time for CPT
99213, except for codes in the range of CPT codes 78000 through 78891
for which we had Harvard survey data and codes for which we had data
from surveys done for the AMA RUC.
<bullet> Based on the judgment of our clinical staff, we calculated
the total physician time for CPT codes 90918 through 90921 using the
work RVUs and the work per unit time for CPT code 99213.
<bullet> Based on the judgment of our clinical staff, we set the
total time associated with the work RVUs for CPT 97001 through 97770 as
follows:
------------------------------------------------------------------------
Time
HCPCS (min)
------------------------------------------------------------------------
97001.......................................................... 30
97002.......................................................... 20
97003.......................................................... 45
97004.......................................................... 30
97010.......................................................... 5
97012.......................................................... 15
97014.......................................................... 13
97016.......................................................... 18
97018.......................................................... 13
97020.......................................................... 14
97022.......................................................... 15
97024.......................................................... 15
97026.......................................................... 10
97028.......................................................... 9
97032.......................................................... 18
97033.......................................................... 14
97034.......................................................... 16
97035.......................................................... 12
97036.......................................................... 15
97039.......................................................... 10
97110.......................................................... 15
97112.......................................................... 15
97113.......................................................... 15
97116.......................................................... 15
97122.......................................................... 15
97124.......................................................... 15
97139.......................................................... 15
97150.......................................................... 15
97250.......................................................... 15
97260.......................................................... 15
97261.......................................................... 15
97265.......................................................... 15
97504.......................................................... 15
97520.......................................................... 15
97530.......................................................... 15
97535.......................................................... 15
97537.......................................................... 15
97542.......................................................... 15
97703.......................................................... 15
97750.......................................................... 15
97770.......................................................... 15
------------------------------------------------------------------------
<bullet> A high percentage of codes performed by the nonphysician
specialties of Independent Physiological Lab, Clinical Psychologist,
and Psychologist (Independent Billing) do not have work RVUs and,
therefore, time data. Because the practice expenses per hour for these
specialties were crosswalked from SMS specialties, when calculating
their practice expense pools we used the maximum clinical staff time
from the CPEP data for the codes that lack work RVUs.
<bullet> We calculated the time for CPT codes 00100 through 01996
using the base and time units from the anesthesia fee schedule and the
Medicare allowed claims data.
13. Other Practice Expense Policies
a. Site-of-Service Payment Differential. Under the physician fee
schedule, if a physician service of the type routinely furnished in
physician offices is furnished in facility settings, our current policy
is that the fee schedule amount for the service is determined by
reducing the practice expense RVUs for the service by 50 percent.
Certain services are excluded from the regulation including rural
health clinic services, surgical services not on the ambulatory
surgical center covered list that are furnished in an ambulatory
surgical center, anesthesia services, and diagnostic and therapeutic
radiology services (see Sec. 414.32 (Determining payments for certain
physician services furnished in facility settings)).
The site-of-service payment differential is a long established
policy to avoid duplicate payments for practice costs while, at the
same time, recognizing that some office practice cost is incurred when
physicians perform procedures outside the office setting. The site-of-
service policy applies to both inpatient and outpatient hospital
settings.
Since the implementation of the physician fee schedule, we have
compiled a list of services furnished outside physician offices that
are subject to the site-of-service payment differential. The current
list includes approximately 700 services.
As part of the resource-based practice expense initiative, we are
proposing to replace the current policy that systematically reduces the
practice expense RVU by 50 percent for certain procedures with a policy
that would generally identify two different levels (facility and
nonfacility) of practice expense RVUs for each procedure code depending
on the site-of-service. In general, we would furnish two levels of
practice expense RVUs per code; one when the procedure is performed in
the office or other site (or nonfacility) if no additional facility fee
is paid and
[[Page 30835]]
another when the procedure is performed out of the office (for example,
in a hospital or an ambulatory surgical center in which the costs of
resources, such as labor, medical supplies, and medical equipment are
paid outside the physician fee schedule and only to the hospital or
ambulatory surgical center).
Some services, by the nature of their codes, are performed only in
certain settings and would have only one level of practice expense RVU
per code. Many of these are evaluation and management codes with code
descriptions specific as to the site of service. Examples of these
codes are the following:
<bullet> Inpatient hospital care for new or established patients
(CPT codes 99221 through 99223).
<bullet> Subsequent hospital care (CPT codes 99231 through 99239).
<bullet> Emergency department services for new or established
patients (CPT codes 99281 through 99285).
<bullet> Critical care services (CPT codes 99291 through 99297).
<bullet> Nursing facility services (CPT codes 99301 through 99303).
<bullet> Subsequent nursing facility care (CPT codes 99311 through
99313).
<bullet> Domiciliary, rest home (CPT codes 99321 through 99333).
<bullet> Home services (CPT codes 99341 through 99350.
We note that office or outpatient evaluation and management
services (CPT codes 99201 through 99215) are used to report services
furnished in the physician office or in a hospital outpatient
department; therefore, these procedure codes will have different levels
of practice expense RVUs. Other services, such as most major surgical
services with a 90-day global period, are performed entirely or almost
entirely in the hospital, and we are generally providing a practice
expense RVU only for the out-of-office or facility setting.
In the majority of cases, however, we would provide both facility
and nonfacility practice expense RVUs. The higher nonfacility practice
expense RVUs are generally used to calculate payments for services
performed in a physician office and for services furnished to a patient
in the patient's home, or facility or institution other than a
hospital, skilled nursing facility, or ambulatory surgical center. For
these services, the physician typically bears the cost of resources,
such as labor, medical supplies, and medical equipment associated with
the physician service.
The lower facility practice expense RVUs generally are used to
calculate payments for services furnished to hospital, SNF, and
ambulatory surgical center patients. The costs for nonphysician
services and other items, including medical equipment and supplies, are
typically borne by the hospital, by the SNF, or the ambulatory surgical
center.
b. Additional Relative Value Units for Additional Office-Based
Expenses for Certain Procedure Codes. Usually office medical supplies
or surgical services in the physician office are included in the
practice expense portion of the payment for the medical or surgical
service to which they are incidental. The November 1991 final rule (56
FR 59522) included a policy that allowed a practice expense RVU of 1.0
to pay for the supplies that are used incident to a physician service
but generally are not the type of routine supplies included in the
practice expense RVUs for specific services. For example, if the
physician performed a cystourethroscopy with a biopsy (CPT code 52204)
in the office and billed for a surgical tray (HCFA Common Procedure
Coding System (HCPCS) code A4550) in addition to the procedure, the
physician would receive approximately $34.86 (an RVU of .95) for the
surgical tray in addition to the payment for the cystourethroscopy with
biopsy. The November 1991 final rule (56 FR 59811) listed 44 procedure
codes that qualified for additional RVUs if furnished in the physician
office. This list was expanded in the December 1993 final rule (58 FR
63854) to include several cystoscopy codes. Included in this list of
procedures for which an additional amount for supplies may be paid if
performed in a physician office are closing a tear duct (CPT code
68671) and billing for a permanent lacrimal duct implant (HCPCS A4263)
and inserting an access port (CPT code 36533) and billing for an
implantable vascular access portal/catheter (A4300). These supplies
were given the same RVU as HCPCS code A4550.
We are proposing to revise this policy under the resource-based
practice expense system. We believe the supply costs that this policy
is designed to cover were included in the supply inputs identified by
the CPEPs and the AMA's SMS survey. Thus, they were included in the
practice expense RVUs for each related procedure code. Therefore, we
are proposing to discontinue separate payment for supply codes A4263,
A4300 and A4550.
c. Anesthesia Services. Although physician anesthesia services are
paid under the physician fee schedule, these services do not have
practice expense RVUs. Rather, payment for physician anesthesia
services is determined based on the sum of allowable base and time
units multiplied by a locality-specific anesthesia CF.
Since the beginning of the physician fee schedule, overall budget
neutrality and work adjustments have been made to the anesthesia CF and
not to the base and time units. We are proposing to follow the same
process and make an adjustment to the anesthesia CF to move anesthesia
services under the resource-based practice expense system. The
adjustment to the anesthesia CF is 3.5 percent.
14. Refinement
Section 4505(d)(1)(C) of the BBA requires the Secretary to develop
a refinement process to be used during each of the 4 years of the
transition period. In this section, we will describe those aspects of
this proposed rule that we believe are subject to refinement as well as
our proposed process for refinement during the coming year. In light of
the complexity of the issues associated with establishing the initial
proposed practice expense RVUs, we believe it is premature to propose,
in this proposed rule, the refinement process for subsequent years of
the transition period. We also believe it would be premature to
finalize the practice expense RVUs before the fall of 1999. Therefore,
we will keep the practice expense RVUs as interim RVUs until at least
the fall of 1999. We also are open to extending the period during which
the practice expense RVUs are interim beyond 1999 if we believe that
more time is needed to identify and correct errors.
We are particularly interested in receiving comments on our
proposed refinement process for this year, and we are soliciting
recommendations for the process in subsequent years. Based on our
analysis of comments we receive, we hope to describe our plans for the
entire refinement process in the final rule.
a. Issues Involved in Refinement. We believe the refinement process
for practice expense RVUs will enable us to:
<bullet> Review and refine practice expense/hour data.
<bullet> Obtain and review practice expense/hour data for
specialties or practitioners not included in the SMS survey.
<bullet> Address anomalies, if any, in the code-specific Harvard/
RUC physician time data.
<bullet> Address anomalies, if any, in the code-specific CPEP data
on clinical staff types and times, quantity and cost of medical
supplies, and quantity and cost of medical equipment.
<bullet> Refine, as needed, our process of developing practice
expense RVUs for codes that were not addressed by the
[[Page 30836]]
CPEP process, for example, codes that were new in 1996, 1997, and 1998.
<bullet> Develop practice expense RVUs for codes that will be new
in 1999 and beyond.
Our plans for each of these six points are as follows:
<bullet> Refinement of the practice expense/hour data. The practice
expense/hour data are based on the SMS survey. (These data can be found
in Table 1). Although the SMS survey was not designed to support the
development of practice expense RVUs, we believe it is the best
available source of data on actual practice costs that allows us to
recognize all staff, equipment, supplies, and expenses, not just those
that can be tied to specific procedures. In fact, we believe one
advantage of the SMS data is that they were collected before this
proposed rule.
The SMS survey data used in this proposed rule do not include the
practice expense information on all specialties recognized by Medicare.
However, for certain larger specialties, for example, family practice
and general surgery, the sample of physicians surveyed is of sufficient
size to serve as the basis of the practice expense/hour calculation in
the short term. For those larger specialties, we are unlikely to make
any changes in the practice expense/hour calculation in the final rule
to be published this fall. In the long term, specifically, 1999 and
beyond, we are prepared to refine the practice expense/hour data of the
larger specialties if we receive compelling evidence that the SMS data
are incorrect. Any arguments that the practice expense/hour for a given
specialty should be changed would be strengthened by the submission of
survey data comparable to the SMS that include data for a range of
specialties expected to gain and lose Medicare revenue.
We are concerned that the validity of future SMS surveys could be
affected if we decided to explicitly link the data collected to future
revisions of the Medicare fee schedule. Also, SMS is a physician level
survey, and physicians in groups are asked for their share of expenses
rather than the practices' expenses. Practice level data may provide a
better basis for constructing practice expense RVUs. We invite comments
on potential revisions to the SMS survey or alternative sources of data
that could be used for long term refinement. Finally, because the
calculation of the practice expense/hour is so critical to our
methodology, we also invite comment on the need to confirm, through
audit or other means, the survey data that would be used for long term
refinement.
<bullet> Refinement of the crosswalk for the practice expense/hour
data. The SMS data we used for this proposed rule do not include data
for all specialties that are recognized by Medicare, and they do not
include data on nonphysician practitioners who are paid under the
physician fee schedule. To develop this proposal, it was necessary to
crosswalk certain specialties and nonphysician practitioners to the
practice expense/hour data we developed for the specialties included in
the SMS. We invite comments on the appropriateness of our crosswalks.
Any arguments that the practice expense/hour data should be changed
would be strengthened by the submission of survey data comparable to
the SMS data.
<bullet> Refinement of the physician time data. The number of
practice expense RVUs assigned to the services performed by a given
specialty is determined by the practice expense/hour data from the SMS
and the physician time data for each of the codes. The physician time
data are based on the Harvard resource-based RVS study and RUC survey
data that were developed as part of the refinement of the work RVUs. We
are confident that these data are accurate although there may be some
codes for which the final work RVUs we have assigned may be
inconsistent with the time data. We will accept comments on the code-
specific physician time data but must point out that any proposed
revisions to the time data have implications for the work RVUs assigned
to those codes. We do not intend to revisit work RVU issues that have
been already addressed as part of the 5-year review. (Total physician
time data can be found in the ``Total Physician Time'' file located on
the HCFA Homepage. Specific instructions for accessing this and other
Internet files referred to in this proposed rule can be found at the
end of this refinement section.)
<bullet> Refinement of the CPEP data. The identification and
correction of errors, if any, in the code-specific CPEP data on
clinical staff types and times, quantity and cost of medical supplies,
and quantity and cost of medical equipment has its principal effect on
the relative relationship of the practice expense RVUs assigned to
services performed by a given specialty.
It is important to understand that the allocation of practice
expense RVUs at the code level is based on CPEP data that have not been
revised or edited in any fashion. We have not made any revisions or
edits for two main reasons. First, we received many comments in
response to last year's proposed rule that objected to the data
reasonableness edits and caps that were part of our proposal. Second,
we received many comments in response to June 1997 proposed rule that
objected to our decision to exclude from the CPEP data the direct
inputs for medical equipment, medical supplies, and clinical staff
recorded for hospital patients. In addition, we found this decision to
be quite controversial in subsequent meetings with representatives of
various specialty societies. Under our proposed methodology that begins
with the total practice expense costs, the question as to the
appropriateness of including the direct inputs for medical equipment,
medical supplies, and clinical staff in the inputs for hospital
patients is much less important because the inclusion of the data
impacts the distribution of practice expense RVUs across the entire fee
schedule only to the extent codes are performed by more than one
specialty.
For example, if a given specialty performs cardiovascular
procedures, including time for nursing staff in the hospital for these
procedures allocates more of the fixed practice expense pool of dollars
for that specialty to these procedures, leaving fewer dollars for the
other codes performed by that specialty. We believe the most
appropriate method for determining the relative relationship of the
RVUs assigned to cardiovascular procedures in this proposed rule is to
rely on the CPEP that developed the inputs for those procedures.
Therefore, the direct inputs for medical equipment, medical supplies,
and clinical staff recorded for hospital patients have not been removed
from the CPEP data.
In deciding not to modify the CPEP data, we recognize the
possibility that the RVUs assigned to some codes will appear to be
incorrect or anomalous. Any apparent errors will be identified and
corrected in response to the comments we receive on this proposed rule
and through our refinement process. We received comments in response to
last year's proposed rule that pointed out apparent errors in the RVUs,
and many of the CPEP inputs were revised during the validation panels
we conducted in October 1997. We have not incorporated any of those
revisions to the data primarily because our methodology for developing
RVUs has been revised, and we were not convinced that all the revisions
that occurred during the validation panels were correct. To the extent
that commenters believe that previously submitted comments are still
valid or that data revisions that occurred during the validation panels
are still
[[Page 30837]]
appropriate, we request that they again be brought to our attention in
response to this proposed rule.
While we will accept comments on any code-specific data, we
recommend that commenters focus their attention during this comment
period on high-volume services with large aggregate expenditures under
Medicare. We will review the comments with the assistance of our
carrier medical directors. Time constraints preclude convening multiple
specialty panels to assist us in our review of the comments. However,
as noted above, the practice expense RVUs would be interim values for
at least 1999, including those we change as a result of our review of
the comments.
Because all of the practice expense RVUs will be interim during
1999, commenters will have another opportunity to identify errors in
the code-specific CPEP data during the comment period of the final rule
with comment period to be published in the fall of 1998. We believe
that the codes identified as possible errors during the comment periods
of the proposed rule and the final rule will constitute the universe of
codes whose code-specific CPEP data should be reviewed. In other words,
although we may keep all the practice expense RVUs interim beyond 1999
as we refine other aspects of the physician fee schedule, it is not our
intention to continually review the inputs for all the codes on the fee
schedule on an annual basis.
We do believe it is important to have the advice of practicing
physicians on the appropriateness of recommended changes to the CPEP
inputs. We have two principal options for obtaining that advice. The
first option would be for us to convene multiple specialty panels to
review the recommended changes. The second option would be to ask the
RUC, or a new organization like the RUC that includes broad
representation across all specialties and includes nonphysician
practitioners, to do this. We believe that under either option, the
panel or panels should include individuals other than physicians, for
example, practice managers or nurses, who could bring additional
experience and expertise to the discussion. The panels would need to
meet no later than the summer of 1999 to consider the comments we
received on both the proposed rule and the final rule. We invite
comments on these options and would welcome any other recommendations.
<bullet> Refinement of the crosswalk for 1996, 1997, and 1998
codes. Because the CPEP process was based on 1995 CPT codes, it was
necessary for us to develop practice expense RVUs for new codes that
were developed for the 1996, 1997, and 1998 CPT books. The process we
used was based on comparing the new codes to other comparable codes for
which we had actual CPEP data. Files containing information about the
crosswalks used for codes that were new in 1996, 1997, and 1998 are
available on the HCFA homepage under the heading ``CPEP Data
Crosswalked to 1998 CPT Codes.'' Since this crosswalk was based on our
judgment rather than actual data, we invite comments on the
appropriateness of our crosswalks. Also, we will accept new code
specific-data on clinical staff types and times, quantity and cost of
medical supplies, and quantity and cost of medical equipment. Any
comments we receive on these codes will be reviewed as part of the
process of review described above.
<bullet> Development of practice expense RVUs for codes that will
be new in 1999 and beyond. There will be new codes included in CPT 1999
for which we will not have practice expense data in time for
publication in the 1998 final rule. We plan to develop interim practice
expense RVUs for these codes by preparing a crosswalk of CPEP data from
existing codes. The crosswalk we use will be available with the final
rule, and the practice expense values for the codes will be subject to
comment. However, the interim values will serve as the basis of payment
during 1999.
We do not believe that preparing a crosswalk of new codes is the
most appropriate method of developing practice expense RVUs for new
codes. However, for 1999, time constraints do not permit any other
approach. Beyond 1999, we would like to develop a process whereby we
receive recommended practice expense RVUs or recommended inputs for
clinical staff types and times, quantity and cost of medical supplies,
and quantity and cost of medical equipment.
For the assignment of work RVUs to new and revised codes, we first
look to the RUC for recommended RVUs. Under that process, codes that
will be new or revised in the next year's CPT are referred from the CPT
editorial panel to the RUC. Specialty societies are informed of these
codes and furnished an opportunity to survey a sample of physicians in
their specialty for the development of recommended RVUs. The entire RUC
then reviews the survey results and forwards the recommended work RVUs
to us.
We then review the RUC's recommended work RVUs with the assistance
of our Medicare carrier medical directors and publish our decisions as
interim RVUs in the final rule for the upcoming year. For example, work
RVUs for codes that were new or revised in CPT 1998 were published as
interim RVUs in the October 1997 final rule.
Publishing RVUs as interim allows the public the opportunity to
furnish comments on the appropriateness of our interim work RVUs.
During the following year, we review any comments we have received with
the assistance of multiple-specialty panels we have convened. We
consider our analysis of any comments on the interim work RVUs and the
advice we receive from the multiple specialty panels in the assignment
of the final work RVUs that are announced in the final rule for the
next year's physician fee schedule.
For practice expense RVUs, we believe there are two principal
options. First, we could continue to crosswalk new codes to existing
codes, publish the results of that crosswalk as interim practice
expense RVUs in the final rule, and review comments we receive with the
assistance of our multiple specialty panels. Second, we could request
the RUC or a RUC-like organization to provide recommended practice
expense RVUs or recommended inputs before publication of the proposed
rule as we do with work RVUs. This approach would allow us to publish
interim RVUs based on the advice of practicing physicians. As with the
work RVUs, any comments we received on the interim RVUs could then be
reviewed with the assistance of HCFA multiple specialty panels. We
invite comments on these options and would welcome any other
recommendations.
b. Example of the Process for Reviewing and Commenting on Practice
Expense Relative Value Units. To facilitate the development of
responses to this proposed rule, to illustrate the issues involved in
refining the RVUs for practice expense, and to furnish further guidance
on the use of the data files that are available on the Internet, we are
furnishing the following analysis of an apparent anomaly in a family of
codes. This analysis is intended to serve as an example of the process
for reviewing and commenting on the practice expense RVUs. We have not
concluded that revisions to the RVUs proposed for this family of codes
are warranted. In the event that no comments are received on the RVUs
for these codes, it is unlikely that we will make any revisions.
In the ophthalmology section of the CPT, there are four codes for
the reporting of eye exams. The codes, brief descriptors, and the
proposed practice expense RVUs follow:
[[Page 30838]]
------------------------------------------------------------------------
Practice
Code Descriptor expense
RVUs
------------------------------------------------------------------------
92002........................... Eye exam, new patient, 0.96
intermediate.
92004........................... Eye exam, new patient, 1.58
comprehensive.
92012........................... Eye exam, established 1.26
patient, intermediate.
92014........................... Eye exam, established 1.25
patient, comprehensive.
------------------------------------------------------------------------
We believe there is a rank order anomaly in this family. We
expected that the practice expense RVUs for new patients would be
higher than the practice expense RVUs for established patients and that
the practice expense RVUs for comprehensive visits would be higher than
practice expense RVUs for intermediate visits. For example, we expected
that CPT code 92014 would have higher practice expenses than CPT code
92012, which is not the case.
To analyze this apparent anomaly, we first reviewed the data on
which specialties furnish the services. These data are located on the
HCFA Homepage under the file name ``Procedure Code Utilization by
Specialty.'' This analysis is important because one potential cause of
an anomaly is that codes in a given family of codes are performed by
physicians in different specialties whose practice expenses per hour
are different. In this case, the dominant specialty performing the
codes is ophthalmology. Optometrists also perform these services but
with less frequency than ophthalmologists. In Table 2, the sum of the
practice expenses per hour for ophthalmology is $131.80, and the sum of
the practice expenses per hour for optometry is $67.50. Although the
practice expense per hour differs for ophthalmology and optometry
because ophthalmology is by far the dominant specialty, this anomaly
cannot be attributed to differences in practice expense per hour.
We next reviewed the code-specific data for in-office services on
clinical labor, equipment, and supplies that are included in the file
``CPEP Data Converted Into 1998 Dollar Amounts,'' located on the HCFA
Homepage. This file is based on the raw CPEP data that have been
converted to monetary amounts. It is considerably easier to review than
the raw CPEP data because it includes fewer data points per code. (The
file containing raw CPEP data, ``Raw CPEP Data'', can also be found in
the HCFA Homepage. Both of these files also contain CPEP data for
supplies and equipment.)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total %
Code Descriptor Clin Eqp Sup services Ophthalmology % Optometry
--------------------------------------------------------------------------------------------------------------------------------------------------------
92002.................................... Eye exam, new patient, 15.44 11.76 3.41 354,000 48 50
intermediate.
92004.................................... Eye exam, new patient, 16.87 12.85 3.41 1,866,000 72 27
comprehensive.
92012.................................... Eye exam, est. patient, 11.15 8.49 27.60 6,022,000 85 13
intermediate.
92014.................................... Eye exam, est. patient, 14.01 10.67 3.41 6,980,000 79 20
comprehensive.
--------------------------------------------------------------------------------------------------------------------------------------------------------
These data show that the relative relationship within the family of
codes appears to be appropriate for clinical staff and equipment.
However, for supplies there is a large discrepancy in that the supply
costs for code 92012 are eight times greater than the supply costs for
the other three codes. To determine whether the supply costs for code
92012 are too high or the supply costs for the other three codes are
too low, it is necessary to review the actual supply inputs assigned to
the codes by the CPEP. These data may be found as a subdirectory of the
file, ``CPEP Data Converted to 1998 Dollars.'' We reviewed the inputs
but have made no judgments about them. We believe the inputs should be
reviewed by the specialties providing the service.
As can be seen in the table, 85 percent of the code 92012 services
are furnished by ophthalmologists, and 13 percent are furnished by
optometrists. The table also shows that this is a high volume family of
codes and that errors in the CPEP data could cause distortions in the
relative relationships of the RVUs assigned to services furnished by
ophthalmologists and optometrists. Under our proposed methodology for
developing RVUs, any revisions to the CPEP data will primarily impact
only those specialties that furnish the service. Thus, if we determine
that the supply inputs for code 92012 include items that are not
typically furnished and are recommended for removal, that will ``free
up'' RVUs that can be redistributed across the other services furnished
by the two specialties.
Conversely, if it is determined that the supply inputs for the
other three codes are missing items that are typically furnished and
are recommended for inclusion, that will require RVUs to be taken from
the other services furnished by the two specialties, not from other
services on the physician fee schedule. We view this as a significant
advantage of our proposed methodology in that the highly contentious
atmosphere of refinement under our earlier methodology is greatly
reduced because, except when multiple specialties perform the same
service, agreement or disagreement with the CPEP inputs of one
specialty does not directly impact the RVUs assigned to services
furnished by other specialties.
c. Information on Accessing Data Files on HCFA's Homepage. The
aforementioned files can be obtained on the HCFA Homepage at
``www.hcfa.gov.'' Following is the step by step process by which the
data files can be accessed.
Step 1: After accessing the HCFA Homepage go to Stats and Data.
Step 2: Go to 1999 Resource-Based Practice Expense.
Step 3: Under Resource-Based Practice Expense, you will have the
option of accessing one of six files related to resource-based practice
expense:
Raw CPEP Data
This file includes the original CPEP data. There are four subgroups
within this file:
Clinical Work
Medical Supplies
Procedure Specific Medical Equipment
[[Page 30839]]
Overhead Medical Equipment
1998 Code Crosswalks
Since the CPEP data were based upon 1995 data, we performed
crosswalks for codes which were new codes in 1996, 1997, and 1998. This
file shows the crosswalks that were used for all codes that were new
after 1995. In addition, this file also contains those codes gap-filled
based on analogous procedures due to an absence of data from the CPEP
process.
CPEP Data Crosswalked to 1998 Codes
This file crosswalks all CPEP data to 1998 codes.
CPEP Data Converted to 1998 Codes Converted Into Dollars
This file converts the CPEP data, crosswalked to 1998 codes, into
dollars.
Procedure Code Utilization by Specialty
This file shows the Medicare allowed services for each procedure
code performed by each specialty.
Time Associated With the Work Relative Value Units
This file contains the time associated with the work RVUs for each
procedure.
15. Reductions in Practice Expense Relative Value Units for Multiple
Procedures
In the June 1997 proposed rule (62 FR 33171), we had recommended
reducing the practice expense RVUs for multiple nonsurgical services
performed at the same time as an evaluation and management service. We
had proposed this as a way to reflect the lower practice costs that
would result when more than one service is performed during a single
patient encounter. Many commenters, as well as the Medicare Payment
Advisory Commission (MEDPAC), recommended that we not implement a
multiple procedure reduction, at least until this issue has been
further studied.
We have decided not to propose this reduction at this time but will
consider it in the future. We invite comments on this specific issue.
The current multiple surgical procedure reduction policy with regard to
physician work is not affected by the practice expense proposal.
16. Transition
Under the transition enacted under BBA 1997, practice expense RVUs
in 1999 are to be based 75 percent on the old method and 25 percent on
the resource-based method. In 2000, the shares are 50 percent old
method and 50 percent resource-based. In 2001, the shares are 25
percent old method and 75 percent resource-based. Beginning in 2002,
practice expense RVUs are entirely resource-based.
In our October 1997 final rule (62 FR 59052), we indicated that the
old method to be used in the formula constitutes the 1998 practice
expense RVUs actually used for payment. We received a comment that
suggested that we consider an alternative interpretation of the law for
purposes of the transition starting point that would eliminate the 1998
changes in practice expenses enacted by BBA 1997. This comment was
based on the theory that the 1998 changes were for 1 year only and not
intended to be included in the base practice expense used for the
transition. This alternative would result in higher payments for
certain specialty procedures and lower payments for medical visits
during 1999, 2000, and 2001. Beginning in 2002, the starting point for
the transition does not matter as practice expenses are entirely
resource-based.
We have considered this suggestion. We do not believe that we can,
as suggested by the commenter, utilize 1997 practice expense RVUs
actually used for payment because we do not believe that we could treat
the reductions enacted in BBA 1997 for 1998 differently from the
similar reductions enacted in OBRA 1993 on practice expenses for 1994,
1995, and 1996. That is, the effects of both amendments should be
included in the base or excluded. We believe that the appropriate
option, other than using 1998 practice expense RVUs, is to exclude the
effects of both the OBRA 1993 and BBA 1997 provisions and revert to
practice expense RVUs as they existed before any amendments. We do not
believe that this is the better alternative. In addition to creating
practical problems of requiring imputation of practice expense RVUs for
the many new codes that have been established between 1991 and 1998, it
would seem contrary to the statute's plain intent of moving toward a
resource-based payment system. This alternative could also potentially
result in a ``yo-yoing'' of practice expense RVUs between 1998 and
future years. Practice expense RVUs for certain procedures explicitly
increased by the Congress in 1998 could be reduced in 1999 only to be
increased again when the practice expense is fully resource-based. If
we were to use 1997 RVUs as the base for the transitions, payments for
office visit procedure codes, for example, would likely decrease
noticeably during 1999, reversing the clear policy the Congress enacted
in BBA 1997 by raising them. To adopt such a construction of the law
would not gradually ``transition'' payments to the new resource-based
system, but instead would represent an abrupt change in direction, a
result at odds with the purpose of having a transition period and with
transitions previously established for payment changes in Medicare. We
find nothing in the legislative history to suggest that the Congress
intended such an atypical transition. Therefore, we propose to use the
1998 practice expense RVUs for purposes of the blend during the
transition years of 1999, 2000, and 2001.
17. Proposed Regulation Revisions
We are proposing to revise Sec. 414.22 (Relative value units
(RVUs)), paragraph (b), (Practice expense RVUs), to state that for
services beginning January 1, 1999, the practice expense RVUs would be
based on a blend of 75 percent of the 1998 code-specific practice
expense RVUs and 25 percent of the relative practice expense resources
involved in furnishing the service. For services beginning January 1,
2000, the practice expense RVUs would be based on a blend of 50 percent
of the 1998 code-specific practice expense RVUs and 50 percent of the
relative practice expense resources involved in furnishing the service.
For services beginning January 1, 2001, the practice expense RVUs would
be based on a blend of 25 percent of the 1998 code-specific practice
expense RVUs and 75 percent of the relative practice expense resources
involved in furnishing the service. For services beginning January 1,
2002, the practice expense RVUs would be based on 100 percent of the
relative practice expense resources involved in furnishing the service.
There would be only one level of practice expense RVUs per code for
the following categories of services: those that have only the
technical component of the practice expense RVUs; only the professional
component practice expense RVUs; certain evaluation and management
services, such as hospital or nursing facility visits that are
furnished exclusively in one setting; and major surgical services. For
other services, there would be two different levels of practice expense
RVUs per code. The lower practice expense RVUs would apply to services
furnished to hospital or ambulatory surgical center patients. The
higher practice expense RVUs would apply to services furnished in a
physician office or services other than visits but performed in a
patient's home and services furnished to patients in a nursing
facility, skilled nursing
[[Page 30840]]
facility, or an institution other than a hospital or ambulatory
surgical center.
18. Response to GAO Recommendations
As previously discussed, the GAO report to Congress on practice
expense made five recommendations for further action; two of these are
short term recommendations that are addressed by this proposed rule and
three are longer term recommendations that will be addressed during the
refinement process. The GAO recommendations are as follows:
<bullet> Short Term Recommendations.
+ Use sensitivity analyses to test the effects of the limits we
placed on the panels' estimates of clinical and administrative labor
and our assumptions about equipment utilization.
We believe that our proposed methodology answers the concerns that
prompted this recommendation. Our current proposal has eliminated the
limits previously placed on the CPEP panels' estimates of clinical and
administrative staff times. In addition, because the proposed
methodology is based on specialty-specific RVU pools, changes in
assumptions about equipment utilization rates would impact
redistributions between specialties only to the extent that codes are
performed by more than one specialty.
+ Evaluate the classification of the administrative labor
associated with billing and other administrative expenses as indirect
expenses, alternative methods for assigning indirect expenses, and
alternative specifications of the regression model used to link the
panels' estimates.
We again believe that our proposed methodology is responsive to
this recommendation. Under our proposal, administrative expenses are
treated as indirect costs, and we have developed a method of assigning
indirect expenses that we believe most closely reflects the various
specialties' actual costs. The third part of the recommendation is now
moot as the current proposed methodology no longer utilizes the linking
algorithm.
<bullet> Longer Term Recommendations.
+ Determine whether changes in hospital staffing patterns and
physicians' use of their clinical staff in hospital settings warrant
adjustments between Medicare reimbursements to hospitals and
physicians. Similarly, we should determine whether physicians have
shifted tasks to nonphysician clinical staff in a way that warrants
reexamining the physician work RVUs.
+ Work with physician groups and the AMA to develop a process for
collecting data from physician practices as a cross-check on the
calculated practice expense RVUs and periodically refine and update the
RVUs.
+ Monitor indicators of beneficiary access to care, focusing on
those services with the greatest cumulative reductions in physician fee
schedule allowances, and consider any access problems when making
refinements to the practice expense RVUs.
We agree with all of these recommendations. One of the major tasks
of any proposed refinement process will be determining when any
additional data are need, whether it be on physician practice patterns
or actual practice expenses. We welcome comments and suggestions on how
best to carry out these recommendations to aid us in developing a
strategy for data gathering in our final rule. We plan to monitor
access to care.
B. Medical Direction for Anesthesia Services
The conditions for payment of medical direction were discussed in
the March 2, 1983 final rule (48 FR 8902) that implemented section 108
of the Tax Equity and Fiscal Responsibility Act (TEFRA) of 1982,
effective October 1, 1983.
TEFRA added section 1887 to the Act and required that we
distinguish between services furnished by physicians to patients that
are now payable under the physician fee schedule and services furnished
by physicians to hospitals that are reimbursed to the hospital on a
prospective payment basis for inpatients or on a reasonable cost basis
for outpatients.
Section 1887 of the Act did not, however, include a reference to
``medical direction.'' This is a term we adopted from the medical
profession that refers to the necessary level of direct involvement of
the anesthesiologist in each of two to four concurrent anesthesia
procedures so that the service meets the definition of physician
services as required by section 1887 of the Act.
Our definition of medical direction closely followed the standards
of anesthesia care team practice promulgated by the American Society of
Anesthesiologists (ASA).
The conditions for payment of medical direction are included in
Sec. 415.110 (Conditions for payment: Medically directed anesthesia
services). For each patient, the physician must furnish seven kinds of
services, and the physician may not perform any other services while he
or she is directing the concurrent procedures unless they meet the
exception as noted. The medical direction activities in Sec. 415.110(a)
(Services furnished directly or concurrently) are as follows:
<bullet> Performs a pre-anesthesia examination and evaluation.
<bullet> Prescribes the anesthesia plan.
<bullet> Personally participates in the most demanding procedures
in the anesthesia plan, including induction and emergence.
<bullet> Ensures that any procedures in the anesthesia plan that he
or she does not perform are performed by a qualified individual as
defined in program operating instructions.
<bullet> Monitors the course of anesthesia at frequent intervals.
<bullet> Remains physically present and available for immediate
diagnosis and treatment of emergencies.
<bullet> Provides indicated post-anesthesia care.
The regulations currently refer to these conditions as applying to
services furnished directly or concurrently. The reference to services
furnished directly is not correct. It suggests that the physician
personally performing the anesthesia services only has to provide the
same kind of services as the physician medically directing the
anesthesia service. In fact, the physician personally performing the
anesthesia service must perform the entire anesthesia service alone.
This policy is included in Sec. 414.46(c)(1)(i) (Additional rules for
payment of anesthesia services, Physician personally performs the
anesthesia procedure). Therefore, we are proposing to delete the
reference in the regulations to services furnished directly.
The December 1995 final rule (60 FR 63152) included the policy to
allow the physician's medical direction of a certified registered nurse
anesthetist (CRNA) performing a single anesthesia service. However,
this provision did not take effect until January 1, 1998. This policy
was incorporated in Sec. 414.46(d)(iii) (Additional rules for payment
of anesthesia services, Anesthesia services medically directed by a
physician). A program memorandum explaining this policy was issued to
the Medicare carriers in January 1998.
We are revising Sec. 415.110 (Conditions for payment: Medically
directed anesthesia services) so that it is consistent with
Sec. 414.46(d)(iii) by stating that medical direction can apply to the
single anesthesia service furnished by a CRNA.
The Omnibus Budget Reconciliation Act of 1993 (OBRA 1993) added
section 1848(a)(4)(Special Rule For Medical Direction) to the Act. This
section of the
[[Page 30841]]
Act specified the calculation of the payment allowances for medical
direction services on or after January 1, 1994. Thus, the specific
payment policy is specified in the law. The law provides that the
medical direction of the performance of an anesthesia service furnished
on or after January 1, 1998, is 50 percent of the fee schedule amount
that would have been paid if the anesthesia service was furnished by
the physician alone.
Both the ASA and the American Association of Nurse Anesthetists
(AANA) have pointed out that the current requirements are outdated and
too restrictive. The current requirements are oriented to the
administration of a general anesthetic, which was the predominate mode
of practice when the regulations were originally implemented. There are
other types of anesthesia, such as regional, spinal or epidural
anesthesia, and monitored anesthesia care, which are becoming more
common and for which the current requirements are not completely
appropriate. For example, in monitored anesthesia care, there is no
definable emergence as there is for general anesthesia.
Also, the AANA has advised us that requiring the presence of the
anesthesiologist for induction for all cases may not be appropriate and
may delay the start of surgery and result in the inefficient use of
operating room time. In addition, the ASA has advised us that neither
the regulations nor the operating instructions explain the level of
documentation required by the anesthesiologist to support the payment
for the medical direction service. The ASA believes that the lack of
instructions for medical documentation and the concerns about payment
audits have reportedly prompted anesthesiologists to overly document
anesthesia records.
The ASA and the AANA have reached consensus on a revised
recommended set of medical direction requirements. We have reviewed
their recommendations and are proposing to revise our regulations in
Sec. 415.110 (Conditions for payment: Anesthesia services) to reflect
current anesthesia practice arrangements. Namely, we would:
<bullet> Provide that the physician either perform the pre-
anesthesia examination and evaluation or review one performed by
another qualified individual.
<bullet> No longer require the physician to be present during
induction and emergence.
<bullet> Require that the physician monitor the course of
anesthesia at intervals medically indicated by the nature of the
procedure and the patient's condition.
C. Separate Payment for Physician Interpretation of an Abnormal
Papanicolaou Smear
With the exception of hospital inpatients, we currently do not
allow separate payment for the physician's interpretation of an
abnormal Papanicolaou (Pap) smear.
About 10 percent of Pap smears are abnormal and are interpreted by
a physician, usually a pathologist. If a physician interprets an
abnormal Pap smear for a patient, other than a hospital inpatient,
payment for the physician interpretation (and the underlying test) is
made under the clinical laboratory fee schedule payment for the Pap
smear test. The physician negotiates with the laboratory for payment
for the physician service.
The clinical laboratory fee schedule allowances were initially
derived from the 1984 prevailing charges made by independent
laboratories for the Pap smear test. Historically, independent
laboratories did not bill separately for the physician interpretation
of the abnormal Pap smear; thus, no separate allowance was established.
Therefore, the initial clinical laboratory fee schedule allowances
reflect payment for both the test and any associated interpretation.
The 1998 clinical fee schedule national allowance for the Pap smear
test is $7.15. The 1998 physician fee schedule national allowance for
the physician interpretation of the abnormal Pap smear for a hospital
inpatient is $28.62.
The College of American Pathologists requested we recognize
separate payment for the physician interpretation of the abnormal Pap
smear in all settings. We believe this proposal would establish an
understandable and uniform definition of physician services across
sites. Therefore, we are proposing to recognize, under the physician
fee schedule, separate payment for the physician interpretation of an
abnormal Pap smear in all settings.
The Pap smear test may be furnished by a hospital or an independent
laboratory. The independent laboratory could bill for the complete
service: the technical component (the performance of the test) and the
professional component (the interpretation of the test) furnished by
the independent laboratory's pathologist. For services to hospital
patients, the Pap smear interpretation usually is furnished by the
hospital pathologist who can bill for the professional component of the
service.
D. Rebasing and Revising the Medicare Economic Index
1. Background
a. History. In the 1972 Amendments to the Act (Public Law 92-603)
enacted on October 30, 1972, the Congress mandated the use of an
economic index in determining payment for physician services under
Medicare Part B. Although the 1972 Amendments did not specify the
particular type of index to be used, we established the Medicare
Economic Index (MEI). The MEI follows the recommendations outlined by
the Senate Finance Committee in its report accompanying the legislation
in that it attempts to present an equitable measure for changes in the
costs of physician time and operating expenses.
The current MEI represents a weighted sum of annual price changes
for various inputs needed to produce physician services. Since its
inception, the MEI has consisted of two principal components or expense
categories--physician net income and physician practice expenses.
Physician net income is further delineated into wages and salaries and
benefits. The physician practice expense portion is delineated into six
major categories: (1) Nonphysician employee compensation, which
includes the wages and salaries and benefits of nonphysician employees
in physician offices; (2) office expenses; (3) medical materials and
supplies; (4) professional liability insurance; (5) medical equipment;
and (6) other professional expenses. These broad expense categories are
still the major expense shares in the proposed MEI and are discussed in
greater detail in the following sections.
b. Use of Current Data. The MEI was last rebased and revised in the
November 25, 1992 final rule (57 FR 55896). The current base year for
the MEI is 1989. We believe that it is desirable to rebase and revise
the index periodically so that the expense shares and proxies will
reflect current conditions. For this reason, we are proposing to rebase
the MEI to reflect 1996 physician expenses and review the proxies we
currently use to ensure using the most appropriate proxy for each
expense category. We will continue to adjust the physician and
nonphysician employee compensation for economy-wide labor productivity
to avoid accounting for both physician productivity and economy-wide
productivity in the physician update framework.
The proposed MEI expense categories were derived primarily from the
1997 AMA SMS, which measured physician earnings and practice expenses
for 1996.
[[Page 30842]]
The AMA data were used to set expenditure weights for physician
earnings and the six major physician practice expense categories. To
further disaggregate into subcategories reflecting more specific
physician expenses, we used data from the 1992 Asset and Expenditure
Survey, the 1996 Bureau of the Census Current Population Survey, the
1997 Bureau of Labor Statistics Employment Cost Index, and the Medical
Economics Continuing Survey data for 1996.
2. Rebasing and Revising Expense Categories
Developing a rebased and revised MEI requires selecting a base year
and determining the number and composition of expense categories. As
mentioned earlier, we are proposing to rebase the MEI to 1996. We chose
1996 as the base year for two main reasons: (1) The 1996 data were the
most recent available data for most of the data sources we are
proposing to use; and (2) the 1996 data were representative of the
changing distribution of physician earnings and practice expenses over
time.
We determined the number and composition of expense categories
based on the criteria used to develop the current MEI expenditure
weights and our other input price index expenditure weights (for more
information on these criteria see the November 25, 1992, proposed rule
(57 FR 55900)). Using these criteria of mutually exclusiveness and
exhaustiveness, we developed the rebased and revised MEI presented in
Table 4.
Table 4.--Revised Medicare Economic Index Expenditure Categories, Weights, and Price Proxies
----------------------------------------------------------------------------------------------------------------
Weights Weights
Expense category -------------------------- Proposed price proxies
1989 (<SUP>1) 1996 (<SUP>1 <SUP>2)
----------------------------------------------------------------------------------------------------------------
Total....................... 100.000 100.000
Physician Earnings (\4\) 54.155 54.460
Wages and Salaries...... 45.342 44.197 AHE--Private (\3\).
Benefits (\5\).......... 8.813 10.263 ECI--Ben: Private (\3\).
Physician Practice Expenses. 45.845 45.540
Non-Physician Employee 16.296 16.812
Compensation.
Employee Wages and 13.786 12.424
Salaries.
Prof/Tech Wages..... 3.790 5.662 ECI--W/S: Private P&T (\3\).
Managers Wages...... 2.620 2.410 ECI--W/S: Private Admin (\3\).
Clerical Wages...... 5.074 3.830 ECI--W/S: Private Clerical (\3\).
Services Wages...... 2.233 0.522 ECI--W/S: Private Service (\3\).
Craft Wages......... 0.069
Employee Benefits 2.510 4.388 ECI--Ben: Priv. White Collar (\3\).
(\5\).
Office Expenses......... 10.280 11.581 CPI(U)--Housing.
Medical Materials and 5.251 4.516 PPI Drugs/PPI Surg. Appl/CPI(U) Med Sup.
Supplies.
Professional Liability 4.780 3.152 HCFA--Prof. Liab. Phys. Prem. Survey.
Insurance.
Medical Equipment....... 2.348 1.878 PPI--Medical Instruments and Equip.
Other Professional 6.890 7.601
Expense.
Automobile.......... 1.400 1.300 CPI(U)--Private Transportation.
All Other........... 5.490 6.301 CPI(U)--All Items less Food and Energy.
----------------------------------------------------------------------------------------------------------------
Footnotes:
(\1\) Due to rounding, weights may not sum to 100.000%.
(\2\) Sources: Socioeconomic Monitoring System 1997 Survey of Physicians, Center for Health Policy Research,
American Medical Association; Anne L. Finger, ``What it costs to run a practice,'' Medical Economics, October
27, 1997; U.S. Department of Labor, Bureau of Labor Statistics; and U.S. Department of Commerce, Bureau of the
Census, 1992 Asset and Expenditure Survey, and 1997 Current Population Survey.
(\3\) Net of change in the 10-year moving average of output per man-hour for the non-farm business sector.
(\4\) Includes employee physician payroll.
(\5\) Includes paid leave.
To determine the expenditure weights, we used currently available
and statistically valid data sources on physician earnings and practice
expenses. While we consulted numerous data sources, we used five
sources to determine the rebased and revised MEI expenditure weights:
(1) The 1997 AMA SMS survey (1996 data); (2) the March 1997 Bureau of
Labor Statistics (BLS) Employment Cost Index; (3) the 1992 Bureau of
the Census Asset and Expenditure Survey (the latest available); (4) the
1996 Bureau of the Census Current Population Survey; and (5) the
Medical Economics continuing survey published October 1997 (1996 data).
No one data source provided all of the information needed to determine
expenditure weights according to our criteria. The use of each of these
data sources is described in detail below.
a. American Medical Association Socioeconomic Monitoring System
Survey. Like the current MEI, the proposed MEI will use AMA data on
mean physician net income (physician earnings) and professional
expenses for self-employed physicians for the major expenditure
categories. The seven major expenditure categories taken from the AMA
data, as shown in Table 1, are physician earnings, nonphysician
employee compensation, office expenses, medical materials and supplies,
professional liability insurance, medical equipment, and other
professional expenses. The weights represent each expenditure
category's proportion of total expenses in 1996. While many of the
category weights have changed since 1989, the effect on the percent
change in the MEI has been minimal, as explained later.
The physician earnings expenditure category in the rebased MEI is
defined differently from the one in the current MEI as it includes
employee physician compensation. Until recently, employee physician
compensation was not available through the AMA survey and was not
included in any AMA expenditure categories. AMA reported these data
separately in 1996. We believe it is appropriate, for our purposes, to
include employee physician compensation in the MEI category of
physician earnings. The physician income (earnings) and overhead
expenses generated by employee physicians are currently included in the
AMA expenditure
[[Page 30843]]
categories. We propose including employee physician payroll in
physician earnings to be consistent with the current methodologies used
in payment under the physician fee schedule. Under the physician fee
schedule, the work RVU is paid based on the service provided and not on
who provides the service. Since employee physicians do the same
services as self-employed physicians, employee physician time would be
included in the work RVU. By including employee physician compensation
in the physician earnings category for the MEI, we have achieved two
goals: (1) Appropriately categorizing these expenses to be consistent
with the physician fee schedule; and (2) adjusting these expenses by
the appropriate price proxies for a physician's own time. A detailed
discussion of the price proxies is presented below.
b. Employment Cost Index Survey. The Employment Cost Index (ECI)
survey has shares of total compensation for wages and salaries and
benefits by private industry health services occupational category that
can be used to allocate the wage and fringe benefit shares for
nonphysician employees. The data on these shares are produced for March
of every year. We determined that March 1997 would be most
representative of the shares in 1996 because the March 1996 data would
miss any changes that occurred during the last three quarters of that
year. The shares are determined from employer costs per hour worked.
Paid leave is defined as a benefit under this survey. Unfortunately,
this survey does not have data for offices of physicians. However, data
are available on wage and fringe benefit shares for total health
services that include hospitals, nursing homes, offices of physicians,
and offices of dentists. While not a direct measure of employee wage
and fringe benefit shares in offices of physicians, the shares for
health services from the ECI survey do provide a normative estimate of
the split between wages and fringes.
In the ECI survey for total health services, the wage and fringe
benefit split of compensation was 73.9 percent and 26.1 percent,
respectively. For comparison purposes, when we included paid leave as
part of wages, these shares were very similar to nonphysician employee
wage and fringe benefit share data from two physician group practice
studies. Based on this analysis, we are proposing to use the wage and
fringe benefit shares for total health services from the ECI survey,
with paid leave as a benefit, in the rebased and revised MEI for
nonphysician employee compensation. The wage and fringe benefit shares
for physicians and nonphysician compensation in the current MEI were
developed from a special study conducted by our Office of the Actuary.
These current and revised shares are presented in Table 1.
c. Asset and Expenditure Survey. We are proposing to use the 1992
Bureau of the Census Asset and Expenditure survey to derive an estimate
of the wage and fringe benefit share for physicians under the MEI. The
wage and fringe benefit share for all persons employed in physician
offices is available from the 1992 Asset and Expenditure survey. This
share includes both physicians and nonphysician employees in the
physician office. By aging this share to 1996 using the ECI for wages
and fringe benefits for total health services and moving paid leave
from wages to fringe benefits based on analysis of ECI data on health
services, we were able to develop a wage and fringe benefit share for
physician offices for 1996. The wage share for physician offices was
79.4 percent, and the fringe benefit share 20.6 percent. Using this
wage and fringe benefit share, the wage and fringe benefit share for
nonphysician employees developed from the ECI survey, and the share for
physician and nonphysician compensation developed from the AMA survey,
we were able to impute a wage and fringe benefit share for physicians.
The wage share was 81.2 percent, and the benefit share 18.8 percent for
physicians. We compared these shares to physician group data on
physician wage and fringe benefit shares and found them to be very
consistent. Therefore, we are proposing to use these wage and fringe
benefit shares for physicians in the rebased and revised MEI, as shown
in Table 1.
d. Current Population Survey. We are proposing to use the 1996
Current Population Survey (CPS) from the Bureau of the Census to
determine the distribution of nonphysician employee wages in the
rebased and revised MEI. The 1989 CPS was used to determine the
distribution for the current MEI. The new distribution is presented in
Table 5. Craft and kindred workers are no longer included in the
distribution because their share is not significant.
Table 5.--Percent Distribution of Non-Physician Payroll Expense by
Occupational Group: 1996
------------------------------------------------------------------------
Expenditure
BLS occupational group shares (1)
------------------------------------------------------------------------
Total...................................................... 100.000
Professional and Technical Workers..................... 45.570
Managers............................................... 19.399
Clerical Workers....................................... 30.831
Service Workers........................................ 4.199
------------------------------------------------------------------------
(1) These weights were derived from the 1996 Current Population Survey,
U.S. Bureau of the Census.
e. Medical Economics Continuing Survey. Consistent with the current
MEI, we are proposing to use the Medical Economics Continuing Survey to
determine the weight for automobile (professional car) expenses. We
used the 1996 Continuing Survey published in the October 27, 1997,
Medical Economics (Finger, 1997) to determine a weight of 1.3 percent
in the proposed MEI for automobile expenses, which is nearly identical
to the 1.4 percent share in the current MEI.
3. Selection of Price Proxies
a. Background. After the 1996 cost weights for the revised MEI were
developed, we reviewed the current set of price proxies to determine
whether they were still the most appropriate to monitor the rate of
price change for each expenditure category. As was the case in 1992 (57
FR 55901), most of the indicators we considered are based on BLS data
and are grouped into one of the following five categories:
<bullet> Producer Price Indices (PPIs). PPIs measure price changes
for goods sold in other than retail markets. They are the preferred
proxies for physician purchases at the wholesale level. These fixed-
weight indexes are a measure of price change at the producer or at the
intermediate stage of production.
<bullet> Consumer Price Indices (CPIs). CPIs measure change in the
prices of final goods and services bought by consumers. Similar to the
PPIs, they are fixed-weight. CPIs may not represent the price changes
faced by producers. For this reason, CPIs were used absent an
appropriate PPI or if the expenditure was similar to that of retail
consumers in general, rather than to a purchase at the wholesale level.
<bullet> Average Hourly Earnings (AHEs). AHEs permit the
measurement of changes in hourly earnings for production and
nonsupervisory workers for specific industries as well as the nonfarm
business economy. AHEs are calculated by dividing gross payrolls for
wages and salaries by total hours. The
[[Page 30844]]
series reflects shifts in employment mix and, thus, is representative
of actual changes in hourly earnings for industries or for the nonfarm
business economy.
<bullet> ECIs for wages and salaries. These ECIs measure the rate
of change in employee wage rates per hour worked. These fixed-weight
indices are not affected by shifts in industry or occupation employment
levels.
<bullet> ECIs for employee benefits. These ECIs measure the rate of
change in employer costs of employee benefits such as the employer's
share of Social Security taxes, pension and other retirement plans,
insurance benefits (life, health, disability, and accident), and paid
leave. Like ECIs for wages and salaries, they are not affected by
changes in industry output or occupational shifts.
As with choosing the expenditure categories, choosing appropriate
wage and price proxies for each expense category necessarily involves
making tradeoffs and using judgment. The strengths and weaknesses of
each proxy variable need to be evaluated using several criteria that
can potentially conflict.
The first criterion is relevance. The price variable should
appropriately represent price changes for specific goods or services
within the expense category. Relevance may encompass judgments about
relative efficiency of the market generating the price and wage
increases and may include normative factors relating to fairness.
The second criterion is reliability or low sampling variability. If
the proxy wage-price variable has a high sampling variability or
inexplicable erratic patterns over time, its value is greatly
diminished since it is unlikely to reflect accurately price changes in
its associated expenditure category. Low sampling variability can
conflict with relevance since the more specifically a price variable is
defined in terms of service, commodity, or geographic area the higher
the sampling variability in some cases.
Timeliness of actual published data is the third criterion. For
this reason, monthly and quarterly data take priority over annual data.
The fourth criterion is the length of time the time-series data has
been in use. A well-established time series is needed to assess the
reasonableness of the series and to provide a solid base from which to
forecast future price changes in the series. Forecasting the MEI is
required to make Federal budget and Trustee's report estimates.
The BLS price proxy categories previously described meet the
criteria of relevance, reliability, timeliness, and time-series length.
The price-wage proxies for the rebased and revised MEI (shown in Table
1) are the same as those chosen for the current MEI.
b. Expense Categories. (1) Physician Time
Because the revenue associated with physician time is the single
largest cost component in the MEI (54.5 percent), the selection of the
price proxy for wages and salaries cost category is a major determinant
of the rate of change in the MEI. For that reason, we are furnishing an
extensive discussion of the selection of the price proxy for the wages
and salaries component as we did in the November 1992 final rule (57 FR
55903). We have found no compelling reason to change the wage proxy for
this expense category and offer the same rationale that we used in the
November 1992 final rule.
The legislative history of the MEI reveals Congressional concern
that increases in physician charges are a cause, rather than a result,
of inflation. The following language from the Senate Finance Committee
report accompanying the 1972 Social Security Amendments makes that
point clearly:
The committee * * * believes that it is necessary to move in the
direction of an approach to reasonable charge reimbursement that
ties recognition of fee increases to appropriate economic indexes so
that the program will not merely recognize whatever increases in
charges are established in a locality but would limit recognition of
charge increases to rates that economic data indicate would be fair
to all concerned (emphasis added) and follow rather than lead
inflationary trends. * * * Initially, the Secretary would be
expected to base the proposed economic indexes on presently
available information on changes in expenses of practice and general
earnings levels. * * * S. Rep. No. 1230, 92d Cong., 2d Sess. 190-191
(1972).
There is obvious circularity if increases in prevailing charges are
linked to increases in physician charges, which are then tied to
increases in physician income. The committee's expectation that the
rate of price inflation assigned to the physician time portion of the
MEI be permitted to increase by an amount consistent with increases in
general earnings levels seems to reflect the Congress' preference for
an equitable external price proxy; that is, a compensation proxy based
on compensation outside or external to the physician services industry.
We examined the following three principal alternatives for the wages
and salary component of the physician time cost category:
<bullet> The use of AHEs for production and nonsupervisory workers
in the private nonfarm economy.
This option suggests a standard of payment that implies that price
increases for the physician labor component should be the same as for
workers in the overall economy, that is, general earnings. This option
presumes that the price increase for the physician time category
(excluding fringe benefits) should reflect the changing mix of industry
output and employment. This alternative appears to reflect most closely
the Senate Finance Committee's reference to general earnings levels.
Since earnings are per hour, a constant quantity of labor input per
unit of time is reflected. In addition, the use of the AHEs data is
consistent with the BLS labor productivity measures. The revised MEI as
well as the current MEI incorporates an adjustment for economy-wide
labor productivity to preclude a double-counting of productivity.
Economy-wide wage increases reflect economy-wide productivity
increases. In addition, physician practice productivity increases
associated with the fee-for-service Medicare payment system
automatically result in revenue increases for the individual physician
practices. Economy-wide productivity increases are adjusted out of the
compensation portion of the MEI so that individual physician practices
get all of their own productivity increases, but not economy-wide
productivity increases as well. The adjustment will continue to be for
the 10-year moving average change in productivity.
<bullet> The use of ECIs for wages and salaries of the total
private nonfarm economy.
This option suggests a standard of payment that implies that price
increases for the physician labor component should be the same as that
for workers in a hypothetical, overall economy in which there are no
shifts in the employment patterns of workers. The overall ECI weighs
nine broad occupational categories and permits measurement of the
change in the hourly straight time wage rate for private industry
workers (Nathan, 1987 and Schwenk, 1985). ECIs are unaffected by
changes in occupational employment shifts or industry output shifts.
Therefore, this alternative would not recognize changes in the
composition of the work force over time as intended by the Senate
Finance Committee.
<bullet> The use of an ECI for wages and salaries for private
professional and technical workers.
[[Page 30845]]
This proxy implies that price changes in the physician time
component, excluding fringe benefits, should correspond to those for
private sector professional and technical workers. The professional and
technical workers category is one of the nine categories that comprise
the overall ECI. Physicians are a tiny subset of this occupational
group. The supply, demand, and opportunity cost characteristics of this
broad category, however, may be different from the supply, demand, and
opportunity cost characteristics of an efficient market for physician
services. Most professional and technical workers are in labor markets
where firms compete for employees. Most office-based physicians are
self-employed. Some occupations within the professional and technical
group are in short supply leading to upward pressure on compensation
levels. Use of this price series would take the MEI away from the
general earnings specified in the enacting legislation.
Each of the above options implies a different standard of equity.
In Table 6, we compare the annual rates of change in the MEI using
three different price variables for physician earnings suggested as
options.
Table 6.--Comparison of Annual Percent Changes in the MEI With
Alternative Physician Wage Price Proxies
------------------------------------------------------------------------
Revised MEI with alternative
proxies for physicians' own
time
--------------------------------
ECI:
Year ending June 30 AHE: wages/ ECI: wages/
total salaries salaries for
private for professional
non- total and
farm private technical
------------------------------------------------------------------------
1992................................... 2.8 3.1 3.4
1993................................... 2.2 2.3 2.7
1994................................... 2.1 2.3 2.3
1995................................... 2.0 2.1 2.0
1996................................... 1.9 1.9 1.8
1997................................... 2.3 2.2 2.0
Average:
1992-1997............................ 2.2 2.3 2.4
------------------------------------------------------------------------
The proposed MEI uses AHEs for the private nonfarm economy as the
proxy of choice for the physician wages and salaries component of the
input price index and is the same price measure used in the 1989-based
MEI. In our judgment, this alternative remains the one that most
closely comports with Congressional intent as expressed in the Senate
Finance Committee's 1972 report referenced above. AHEs change in
accordance with market forces associated with changes in the type and
mix of workers. This is not the case with ECIs, since ECIs reflect a
fixed composition of the work force at a given time. Therefore, the
rate of change in an ECI may differ substantially from an actual AHE
measure.
The current MEI uses the ECI for fringe benefits for total private
industry as the price proxy for fringe benefits. We propose using the
same proxy for the 1996-based MEI. This means that both the wage and
fringe benefit proxies for physician time are derived from the nonfarm
private sector and are both computed on a per-hour basis.
(2) Nonphysician Employee Compensation. As in the 1989-based MEI,
we are proposing to use the 1996 Current Population Survey data on
earnings and employment by occupation to develop labor cost shares for
the nonphysician occupational groups shown in Table 5. BLS maintains an
ECI for each of these occupational groups and we are proposing to use
these as price proxies for nonphysician employee wages in the same
manner they are used in the current MEI. We multiplied each of the
occupational cost shares by the changes in the occupational ECI for
that category. These values were summed to yield an overall rate of
price change.
The skill mix shift in physician offices has been substantial in
the last few years as work formerly done in the hospital increasingly
is done in ambulatory settings. These skill mix shifts appropriately
are held constant in this Laspeyres index of nonphysician employees'
wages and salaries. Skill mix shifts that reflect rising intensity of
outputs in physician offices are automatically paid for by higher
charge structures for the more complex mix of service inputs.
Physicians performing more complex services may hire more skilled
employees, and, thus, may tend to charge more for their services.
The current MEI uses the ECI for fringe benefits for white collar
employees in the private sector. Most nonphysician employees in
physician offices are white collar employees. We are proposing to use
the ECI for benefits for white collar employees in the rebased and
revised MEI. Note that we will continue to adjust the nonphysician
employee compensation portion of the MEI by the 10-year moving average
change in economy-wide productivity since physician practice
productivity is being recognized.
(3) Office Expense. Office expenses include rent or mortgage for
office space, furnishings, insurance, utilities, and telephone. We are
proposing the continued use of the CPI-U for housing because it is a
comprehensive measure of the cost of housing including rent, owner's
equivalent rent, insurance, maintenance and repair services, fuels,
utilities, telephones, furnishings, and housekeeping services. This
proxy covers about 80 percent of the population.
(4) Medical Materials and Supplies. This cost category includes
drugs, outside laboratory work, x-ray films, and other related
services. There is no price proxy that includes this mix of materials
and supplies. In the absence of one index, in the 1989-based MEI we
equally weighted the following three price proxies associated with the
medical materials and supplies listed above:
<bullet> The PPI for ethical drugs.
<bullet> The PPI for surgical appliances and supplies.
<bullet> The CPI-U for medical equipment and supplies.
We propose using the same blended proxy for the 1996-based MEI.
(5) Professional Liability Insurance. This cost category includes
costs for professional medical liability or malpractice insurance
premiums including costs associated with self-insurance. Changes in the
cost of medical liability insurance premiums currently are measured
based on our survey of the rate of change in average liability premiums
for $100,000/$300,000 coverage (that is, $100,000 for per-case
limitation and $300,000 for total coverage or the minimum furnished)
among major insurers. We measured change with historical data each
January 1 and interpolated quarterly changes for March, June, and
September.
We improved the professional medical liability index in two major
ways. First, we used actual rates for $1 million/$3 million premiums in
the index for the most current historical period and estimated them for
earlier years. Starting with 1996 levels and 1997 percentage changes,
rates for $1 million/$3 million premiums will be computed; in future
periods we will use premiums for $1 million/$3 million of coverage.
Second, the revised index uses data on a quarterly basis that is
calculated into a four-quarter moving average percent change like all
our other price proxies. We achieve this by tracking the premium
changes that occur during each quarter. We gathered historical premium
data back to 1992 and established average premium levels based on the
mix of physicians by specialty in 1996. We calculated four-
[[Page 30846]]
quarter moving averages and percent changes from 1992 through 1997 to
more accurately forecast changes in premium levels for future budget
and Trustees' report estimates. The previous method obtained the
premium change only for January 1 of each year.
We are proposing the changes described above because we believe
they will improve the quality of measuring change in physician
professional medical liability premiums. Far more physicians have $1
million/$3 million coverage rather than $100,000/$300,000 coverage.
Taking quarterly measurements and computing a four-quarter moving
average percent change is the same methodology used for all the other
price proxies. The resulting series better captures the changes through
the year.
(6) Medical Equipment. Medical equipment includes depreciation,
leases, and rent on medical equipment. We propose to use the PPI for
medical instruments and equipment as the price proxy for this category,
consistent with the price proxy used in the 1989-based MEI.
(7) Other Professional Expenses. This category has two
subcomponents: professional car and ``other.'' The professional car
category includes depreciation and upkeep for the practice-related use
of a professional car. We are proposing the continued use of the CPI-U
for private transportation for this cost category, consistent with the
price proxy used in the 1989-based MEI. This excludes airline fares,
inter-city bus and train transportation, and intra-city bus and train
transportation.
This category also includes the residual subcategory of other
expenses. This residual category includes professional expenses such as
accounting services, legal services, office management services,
continuing education, professional association memberships, journals,
and other professional expenses. In the absence of one price proxy or
even a group of price proxies that might reflect this heterogeneous mix
of goods and services, we use the CPI-U for all items less food and
energy, consistent with the price proxy used in the 1989-based MEI.
4. Summary of Changes
Updating the MEI to the 1996 base year resulted in small changes in
expense category weights. Physician earnings increased slightly from
54.2 percent of the index in 1989 to 54.5 percent in 1996. Physician
practice expenses dropped slightly due to declines in the expense
shares for medical materials and supplies, professional liability
insurance, and medical equipment. These declines were mostly offset by
increases in the expense shares for nonphysician employee compensation,
office expenses, and other professional expenses.
Table 7.--Annual Percent Change in the Current and Revised Medicare
Economic Index
------------------------------------------------------------------------
Current Revised
MEI 89- MEI 96-
Years ending June 30 base % base % Difference
change change
------------------------------------------------------------------------
1985...................................... 3.3 3.2 -0.1
1986...................................... 3.3 3.0 -0.3
1987...................................... 3.0 2.7 -0.3
1988...................................... 3.6 3.4 -0.2
1989...................................... 3.4 3.5 0.1
1990...................................... 3.0 3.4 0.4
1991...................................... 3.2 3.4 0.2
1992...................................... 2.8 2.8 0.0
1993...................................... 2.1 2.2 0.1
1994...................................... 2.1 2.1 0.0
1995...................................... 2.0 2.0 0.0
1996...................................... 2.1 1.9 -0.2
1997...................................... 2.2 2.3 0.1
Average 1985--1997........................ 2.8 2.8 0.0
------------------------------------------------------------------------
The rebased and revised MEI is very similar to the current MEI.
Using the new expense category weights and new proxy for professional
medical liability premiums, the difference in the annual percent change
in the index is within two-tenths of one percent in most years from
1985 through 1997. The average annual percent change from 1985 to 1997
was identical. Thus, this revision and rebasing, while making the
expense shares more timely, has little impact on the percent changes in
the MEI as a whole.
III. Implementation of the Balanced Budget Act of 1997 (BBA 1997)
In addition to the resource-based practice expense relative value
units, BBA 1997 provides for revisions to the payment policy for drugs
and biologicals, a provision allowing private contracting with Medicare
beneficiaries, payment for outpatient rehabilitation services based on
the physician fee schedule, and revisions to our policy for
nonphysician practitioners.
A. Payment for Drugs and Biologicals
Before January 1, 1998, drugs and biologicals not paid on a cost or
prospective payment basis were paid based on the lower of the estimated
acquisition cost (EAC) or the national average wholesale price (AWP) as
reflected in sources such as the Red Book, Blue Book, or Medispan. For
purposes of this discussion, we will use the term ``drugs'' to refer to
drugs and biologicals. Examples of drugs that are paid on this basis
are drugs furnished incident to a physician service, drugs furnished by
pharmacies under the durable medical equipment (DME) benefit, and drugs
furnished by independent dialysis facilities that are not included in
the end-stage renal disease (ESRD) composite rate payment.
Section 4556 of BBA 1997 established payment for drugs not paid on
a cost or prospective payment basis at the lower of the actual billed
amount or 95 percent of the AWP, effective January 1, 1998. In this
proposed rule, we are revising the current regulations at Sec. 405.517
to conform to this statutory change. This regulation would remove the
EAC and provide for payment at the lower of the actual charge on the
Medicare claim or 95 percent of the AWP.
Also, we are proposing to revise the method of calculating the AWP.
Our current regulations provide that, for multiple-source drugs, the
AWP equals the median AWP of the generic forms of the drug. The AWP of
the brand name products is ignored on the presumption the brand AWP is
always higher than the generic AWPs. While this may have been true when
the policy was first promulgated, it is not always true now. Therefore,
we are proposing that the AWP for multiple-source drugs would equal the
lower of the median price of the generic AWPs or the lowest brand name
AWP.
B. Private Contracting With Medicare Beneficiaries
Section 4507 of BBA 1997 amended section 1802 of the Act to permit
certain physicians and practitioners to opt-out of Medicare and to
provide through private contracts services that would otherwise be
covered by Medicare. Under such contracts the mandatory claims
submission and limiting charge rules of section 1848(g) of the Act
would not apply. This section, which was effective on January 1, 1998,
and was implemented through operating instructions, counters the effect
of certain provisions of Medicare law that, absent section 4507 of BBA
1997, preclude physicians and practitioners from contracting privately
with Medicare beneficiaries to pay without regard to Medicare limits.
Specifically, section 1848(g) of the Act restricts the amounts that
can be collected from beneficiaries by nonparticipating physicians who
do not take assignment on the Medicare claim (physicians who take
assignment
[[Page 30847]]
voluntarily agree to accept the Medicare payment amount as payment in
full and collect only deductible and coinsurance amounts from the
beneficiary). Moreover, section 1842(b)(18) requires certain
practitioners to take assignment when they furnish covered services to
Medicare beneficiaries and restricts what they can collect from
beneficiaries to deductible and coinsurance amounts. The statute not
only imposes these rules (without an exception before passage of
section 4507 of BBA 1997), but it also provides strong sanctions for
violation of them. Hence, Medicare law absent section 4507 effectively
precludes a physician or practitioner from privately contracting with a
Medicare beneficiary for the delivery of Medicare-covered items and
services, except in compliance with these rules (for example, to pay
more than the limits set by law). Section 4507 of BBA 1997 permits such
private contracting, provided the requirements of BBA 1997 are met.
The private contracting provision was effective for private
contracts entered into, on, or after January 1, 1998. We implemented it
through a series of operating instructions for Medicare carriers and
information that carriers were instructed to provide to physicians and
practitioners. Specifically, in November 1998, we issued Program
Memorandum No. B-97-9 (change request number 294) that transmitted the
Medicare fee schedule for physician services and contained the fact
sheet that carriers were instructed to send to physicians and
practitioners with the 1998 fee schedule information. This document,
which is commonly called the ``Dear Doctor letter,'' advised physicians
and practitioners of the fee schedule amounts for 1998, the changes to
regulations, and also the important changes that BBA 1997 made to
coverage and payment for physician services, including the private
contracting changes.
Due to the private contracting provisions, we extended the
participating enrollment period to February 2, 1998, to give physicians
sufficient time to consider the changes made by BBA 1997 before making
a participation decision. In January 1998, we issued Program Memorandum
No. B 97-17 (change request number 193), that was devoted in its
entirety to private contracting and not only laid out the processes
that would apply but also answered the most frequently asked questions
about private contracting. Carriers were instructed to share this
information with physicians and practitioners through carrier
bulletins.
Lastly, in April 1998, we issued Program Memorandum No. B 98-12
(change request number 468), which amended the process to be followed
when the carriers receive a claim from a physician or practitioner who
has opted-out of Medicare under the private contracting provision and
thus should not bill Medicare.
We are using this proposed rule to place in regulations the
requirements that section 4507 of BBA 1997 added to sections 1802(b)
and 1862(a)(19) of the Act. In addition to placing the statutory
requirements in regulations, this proposed rule also proposes ancillary
policies that we believe are necessary to clarify what it means when a
physician or practitioner exercises his or her ability to ``opt out''
of Medicare.
There has been a lot of confusion and misinformation about when
private contracts are needed. Before we discuss our proposed rules
governing private contracting, we want to address some of the most
common questions about Medicare claims submission rules and private
contracting.
<bullet> Do the private contracting rules apply to Part A?
No. The Medicare claims submission and private contracting rules
apply only when a physician or practitioner furnishes Medicare-covered
services to a beneficiary who is enrolled in Medicare Part B. They do
not apply to individuals who have only Medicare Part A or to
individuals who are age 65 or over but who do not have Medicare.
Therefore, if the patient is not enrolled in Medicare Part B, a private
contract is not needed for the physician or practitioner to continue to
bill the patient and to charge without regard to the Medicare mandatory
claims submission and limiting charge rules.
The private contracting provision of the statute defines
``beneficiary'' (for purposes of that section only) as a person who is
eligible for Part A or who is enrolled in Part B. However, the private
contracting provisions of the law set aside the mandatory claims and
limiting charge rules that apply only to Part B. Therefore,
notwithstanding the statutory definition of the term ``beneficiary'' to
mean, in part, an individual who is eligible for Part A, as a practical
matter section 4507 applies only to services furnished to an individual
who is enrolled in Part B.
<bullet> Must a physician or practitioner who provides services
that are not covered by Medicare sign a private contract with the
beneficiary and opt-out of Medicare to be paid for noncovered services?
No. Since Medicare rules do not apply to services that Medicare
does not cover, a section 4507 private contract is not needed to bill
for them, and neither the Medicare claims submission nor the Medicare
limiting charges rules apply to these services. A private contract is
needed only for Medicare-covered services and then only if the
physician or practitioner is opting-out or has opted-out.
A physician or practitioner may furnish a service that Medicare
covers under some or many circumstances but that would likely be deemed
as not reasonable and necessary by Medicare in a particular case (for
example, multiple nursing home visits, some concurrent care services).
In that particular case, the physician or practitioner should give the
beneficiary an advance beneficiary notice (ABN) that states the service
may not be covered by Medicare and that the beneficiary will be liable
to pay for the service if it is denied. If the claim is denied by
Medicare, a private contract is not necessary to permit the physician
or practitioner to bill the beneficiary for the service.
<bullet> What are the rules governing claims submission to
Medicare?
There are situations where a physician or practitioner who has not
opted-out of Medicare is not authorized to submit a claim for a covered
item or service provided to a Medicare beneficiary. A beneficiary, for
reasons of his or her own, may decline to authorize the physician or
practitioner to submit a claim or to furnish confidential medical
information that is needed to submit a proper claim to Medicare. For
example, the beneficiary may not want information about the
beneficiary's mental illness or HIV/AIDS status to be disclosed to
anyone. If the beneficiary does not sign the claim or otherwise
authorize the claim submission, the physician or practitioner should
not submit the claim to Medicare. However, the limiting charge would
apply to the service. Moreover, if the beneficiary or his or her legal
representative later decides to authorize the submission of a claim for
the service and asks the physician or practitioner to submit the claim,
the physician or practitioner must do so.
Where the beneficiary authorizes the claim submission, physicians
and practitioners must submit claims for services furnished to an
individual enrolled in Medicare Part B unless they have opted-out of
Medicare under the private contracting provisions of the law.
Physicians and practitioners who furnish services to a Medicare
beneficiary need not submit claims to Medicare in the following cases:
[[Page 30848]]
<bullet> The beneficiary is not enrolled in Medicare Part B;
Medicare limiting charge does not apply.
<bullet> The beneficiary refuses to authorize the physician or
practitioner to submit a claim for a covered service to Medicare;
Medicare limiting charge does apply.
<bullet> The service is categorically noncovered (for example,
hearing aids and meals on wheels for diabetics); Medicare limiting
charge does not apply.
<bullet> The service is not covered because the beneficiary is
enrolled in a Medicare risk HMO and the HMO will not pay for the
service because the physician or practitioner is outside of the HMO's
network; Medicare limiting charge does not apply.
Provisions of the proposed rule relating to private contracting.
Definitions
In Sec. 405.400, we define certain terms. We are proposing to
define ``beneficiary'' to mean an individual who is enrolled in Part B
of Medicare. As we discussed above, the statute's definition of the
term has created considerable confusion about whether physicians must
opt-out of Medicare to charge individuals who are over age 65 and
eligible for Part A of Medicare but who are not enrolled in Part B of
Medicare. We believe it is necessary to define the term ``beneficiary''
as being limited to an individual who is enrolled in Part B of Medicare
in order to avoid continued confusion on this issue. We believe that
having a definition that differs from the statute's definition is
justified because the context in which the definition is used is that
of Part B claims submission rules, Part B limiting charges, and
coverage of Part B services. None of these policies is applicable to
individuals who are not enrolled in Part B of Medicare.
We propose to define ``emergency care services'' as being services
furnished to an individual who has an ``emergency medical condition''
as that term is defined in Sec. 489.24. Reliance on the longstanding
definition of emergency medical condition is, we believe, an
appropriate and useful way to define emergency care services.
We are proposing to define ``legal representative'' to mean an
individual who has been appointed as the Medicare beneficiary's legal
guardian under State law, or who has been granted a power of attorney
from the beneficiary, which power of attorney is sufficient to permit
the individual to enter into private contracts on the Medicare
beneficiary's behalf. This is necessary to clarify that, if a
beneficiary has a legal representative, that party can act on the
beneficiary's behalf when signing a private contract. We recognize that
this is a strict standard and we invite comments on it. However, our
concern is that we ensure that only parties who were authorized to make
legal and financial commitments on behalf of the beneficiary be
permitted to sign private contracts on a beneficiary's behalf since
signing such a contract may incur a significant debt for a beneficiary.
We are defining the term ``opt-out'' to mean the status of meeting
the conditions specified in Sec. 405.410. When the physician or
practitioner meets these conditions, he or she ceases to be bound by
Medicare's mandatory claims submission rule and, in the case of a
physician, the limiting charge rule or, in the case of a practitioner,
the mandatory assignment rule.
We are defining ``participating physician'' to mean a physician as
defined in this section who has signed an agreement to participate in
Part B.
We are defining ``physician'' to mean a doctor of medicine or a
doctor of osteopathy (who is legally authorized to practice as such in
the State in which he or she practices). This is the statutory
definition of the term for purposes of this section as specified in
section 1802(b)(5)(B) of the Act.
We are defining ``practitioner'' to mean any of the following to
the extent that the individual is legally authorized to practice as
such by the State where he or she furnishes services: a physician
assistant, nurse practitioner, clinical nurse specialist, certified
registered nurse anesthetist, certified nurse midwife, clinical
psychologist, and clinical social worker. These practitioners are those
included in the statutory definition of practitioner for this purpose
in section 1802(b)(5)(C) of the Act, that incorporates by reference
those practitioner types listed in section 1842(b)(18)(C) of the Act.
We are defining ``private contract'' to mean a document that meets
the criteria in Sec. 405.415.
We propose to define ``properly opt-out'' to mean to fully complete
the requirements in Sec. 405.410, each of which must be met for the
physician or practitioner to opt-out of Medicare and furnish items or
services under a private contract.
We propose to define ``properly terminate opt-out'' to mean to
fully complete the requirements in Sec. 405.445, each of which must be
met for the physician or practitioner who has opted-out of Medicare to
terminate his or her opt-out.
We are proposing to define ``urgent care services'' as services
that are provided to an individual who requires services to be
furnished within 12 hours in order to avoid the likely onset of an
emergency medical condition.
We also adopted the concept of ``emergency medical condition'' as
defined in Sec. 489.24 to help define urgent care services because the
former term has a longstanding history of use in Medicare with respect
to when a hospital must furnish emergency care to an individual who
appears at its door (specifically, the ``anti-dumping'' rules). We have
no standardized definition of ``urgent care services.'' We have been
unable to find a definition of an ``urgent care service'' in standard
usage. However, we think that an urgent care service would
appropriately be any service that needs to be furnished without
significant delay so as to avoid the onset of an emergency medical
condition. Therefore, we are proposing that an ``urgent care service''
is one that needs to be furnished within 12 hours of the determination
of need in order to avoid the individual's condition from becoming an
emergency medical condition. The chief distinction between urgent care
services and emergency care services is that urgent care services do
not have to be furnished ``immediately'' as do ``emergency care
services.''
General Rules
In Sec. 405.405, we specify the general rules that apply to private
contracting. Specifically, in Sec. 405.405(a), we state that a
physician or practitioner may enter into one or more private contracts
with Medicare beneficiaries for the purpose of furnishing items or
services that would otherwise be covered by Medicare when the
requirements of these rules are met. This is required by section
1802(b)(1)of the Act.
In Sec. 405.405(b), we specify that a physician or practitioner who
enters into at least one private contract with a Medicare beneficiary
under this provision, and who submits one or more affidavits in
accordance with these rules, opts out of Medicare for a 2-year period.
This is required by section 1802(b)(3)(B)(ii) of the Act. We also
specify that the physician's or practitioner's opt-out may be renewed
for subsequent 2-year periods. Since the statute specifies that the
physician or practitioner who meets the criteria for private
contracting cannot be paid by Medicare for a 2-year period and does not
address continuance of this period, we have chosen to make the opt-out
period 2 years but to permit subsequent opt-out periods. There is no
limit on the number of subsequent periods for which a physician or
practitioner may opt-out.
[[Page 30849]]
In Sec. 405.405(c), we specify that both the private contracts
described in paragraph (a) and the physician's or practitioner's opt-
out described in paragraph (b) are null and void if the physician or
practitioner fails to complete opt-out in accordance with these rules
or fails to remain in compliance with the conditions for opting-out. We
specify the results of failure to properly opt-out or to maintain the
conditions for opting-out in Sec. 405.430 and Sec. 405.435. Sections
1802(b)(2) and (b)(3)(A) of the Act, the criteria that governs the
private contract and the affidavit, must be met by physicians and
practitioners that want to opt-out and to privately contract with
Medicare beneficiaries.
In Sec. 405.405(d), we specify that services furnished under
private contracts meeting the requirements of this Subpart are not
covered services under Medicare and that no Medicare payment will be
made for such services either directly or indirectly. This implements
section 1862(a)(19) of the Act, which causes services furnished under
private contracts by physicians and practitioners who opt-out to be
excluded from coverage under Medicare.
Conditions for Opting-Out of Medicare
In Sec. 405.410, we specify the conditions that must be met for a
physician or practitioner to opt-out of Medicare and to furnish
services under private contracts with Medicare beneficiaries.
Specifically, in Sec. 405.410(a), we specify that each private contract
between a physician or a practitioner and a Medicare beneficiary must
meet the specifications of Sec. 405.415. In Sec. 405.410(b), we specify
that the physician or practitioner who wants to privately contract with
Medicare beneficiaries must submit to Medicare one or more affidavits
that meet the specifications of Sec. 405.420. The physician or
practitioner must submit an affidavit to each Medicare carrier to which
the physician or practitioner submits claims for Medicare payment.
In Sec. 405.410(c), we specify that a nonparticipating physician or
a practitioner may opt-out of Medicare at any time. We also specify
that the 2-year opt-out period begins the date the affidavit meeting
the requirements of Sec. 405.420 is signed, as long as the affidavit is
timely filed (that is, within 10 days after the first private contract
is entered into). In addition, we specify that if any required
affidavit is not timely filed, the 2-year opt-out period begins when
the last of the affidavits is filed. In this event, the private
contracts signed by the parties before the last required affidavit is
properly filed become effective upon the filing of the last required
affidavit, and the furnishing of any items or services to Medicare
beneficiaries under contracts before the last required affidavit is
properly filed are subject to standard Medicare rules. Section
1802(b)(3)(B)(ii) provides that the opt-out period begins when the
affidavit is signed, and section 1802(b)(3)(B)(iii) of the Act
specifies that the affidavit must be filed within 10 days of the date
the first private contract is signed.
In Sec. 405.410(d), we specify that a participating physician may
opt-out of Medicare at the beginning of any calendar quarter, provided
the affidavit described in Sec. 405.420 is submitted to Medicare at
least 30 days before the beginning of such quarter. Private contracts
signed by the parties before the beginning of the calendar quarter
become effective at the beginning of such calendar quarter, and the
furnishing of any items or services to Medicare beneficiaries under
these contracts before the beginning of that calendar quarter is
subject to standard Medicare rules.
It is necessary to treat participating physicians differently from
nonparticipating physicians because each participating physician has
entered into a contract with Medicare to be paid at the full fee
schedule for the services they furnish to Medicare beneficiaries
(rather than at 95 percent of the payment amount for nonparticipating
physicians). When a participating physician opts-out of Medicare, he or
she, in effect, terminates his or her participation agreement with
Medicare since he or she no longer agrees to accept assignment on all
services furnished to Medicare beneficiaries. When a participating
physician opts-out of Medicare, the carrier (that is, each applicable
carrier) must make systems changes to ensure the system pays the
physician at the higher participating-physician rate for the period
before the effective date of the opt-out, pays the physician as a
nonparticipating-physician for emergency and urgent care services
effective the date of the opt-out, and does not pay at all for all
other items and services effective the date of the opt-out. Therefore,
carriers need at least 30 days advance notice when a participating
physician opts-out to ensure that the systems changes are made
correctly. Moreover, carriers generally make systems changes no less
frequently than at the beginning of each calendar quarter. Therefore,
participating physicians must provide 30 days notice that they intend
to opt-out at the beginning of the next calendar quarter for the
changes to be made properly. We do not anticipate that this requirement
will cause significant hardship on participating physicians who choose
to opt-out or on beneficiaries who choose to privately contract with
them.
Requirements of Private Contracts
In Sec. 405.415, we are specifying criteria for a physician or
practitioner to opt-out of Medicare. To opt-out of Medicare, the
physician or practitioner must meet all of the criteria in this
section.
In Sec. 405.415, we specify the requirements for a private
contract. In Sec. 405.415(a) we specify that it must be in writing, in
accordance with section 1802(b)(2)(A)(i) of the Act. In addition, we
are proposing requiring that the contract be printed in sufficiently
large type to ensure that beneficiaries are able to read the contract.
In Sec. 405.415(b), we specify that, as required by 1802(b)(2)(B)
of the Act, it must state whether the physician or practitioner has
been excluded from Medicare under section 1128 of the Act.
In Sec. 405.415(c), we specify that, as required by
1802(b)(2)(B)(ii) of the Act, it must state that the beneficiary or
legal representative accepts full responsibility for payment of the
physician's or practitioner's charge for the services furnished.
In Sec. 405.415(d), as required by section 1802(b)(2)(B)(iii) of
the Act, it must state that the beneficiary or legal representative
understands that there are no limits on what the physician or
practitioner may charge for items or services furnished by the
physician or practitioner.
In Sec. 405.415(e), we specify that, as required by
1802(b)(2)(B)(i) of the Act, it must state that the beneficiary or
legal representative agrees not to submit a claim to Medicare nor to
ask the physician or practitioner to submit a claim to Medicare.
In Sec. 405.415(f), we specify that, as required by section
1802(b)(2)(B)(ii) of the Act, it must state that the beneficiary or
legal representative understands that no Medicare payment will be made
for any services furnished by the physician or practitioner, although
such Medicare-covered services would likely be covered and paid by
Medicare if they were provided by a physician or practitioner who had
not opted-out of Medicare.
In Sec. 405.415(g), we specify that, in accordance with section
1802(b)(2)(B)(v) of the Act, it must state that the beneficiary or
legal representative enters into this contract with the knowledge that
he or she has the right to obtain Medicare-covered items and services
[[Page 30850]]
from physicians and practitioners who have not opted-out of Medicare.
In Sec. 405.415(h), we propose that the private contract contain
the beginning effective date and expiration date of the opt-out period.
The private contract must expire on the expiration date of the opt-out
period since, after the expiration of the opt-out period, the physician
or practitioner is no longer authorized to privately contract unless he
or she enters into a new opt-out period.
In Sec. 405.415(i), we specify, in accord with section
1802(b)(2)(B)(iv) of the Act, that the private contract must state that
the beneficiary understands that Medigap plans do not, and that other
supplemental insurance plans may elect not to, make payments for such
items and services because payment is not made by Medicare.
In Sec. 405.415(j), we specify that the contract must be signed by
the beneficiary or by the beneficiary's legal representative and by the
physician or practitioner. Section 1802(b)(2)(A)(i) of the Act
expressly requires that the contract must be signed by the beneficiary.
Although there is no parallel express requirement for the physician or
practitioner, we believe that such a requirement is implicit in the
statute, and we are, therefore, proposing that the physician or
practitioner also sign the contract.
In Sec. 405.415(k), in accordance with 1802(b)(2)(A)(iii), we
specify that the contract must not have been entered into during a time
when the beneficiary requires emergency care services or urgent care
services.
405.415(l), we propose that the beneficiary or legal representative
must receive a copy of the contract before items or services are
furnished under the contract. This is standard practice when parties
sign binding contracts, and we believe it is important in this case so
that the beneficiary or family members have the contract available if
questions about charges for the services furnished arise.
In Sec. 405.415(m), we propose that the physician or practitioner
must retain a copy of each private contract for the duration of the
opt-out period to which the contract applies. Physicians and
practitioners may want to retain the private contracts for a longer
period of time in case a beneficiary disputes whether a valid contract
was signed.
In Sec. 405.415(n), we propose that the physician or practitioner
must permit us to inspect each such contract upon request. We propose
these requirements to ensure that the contracts will be available if
there are allegations that the physician or practitioner has failed
properly opt-out or maintain opt-out or if there is need to review them
to process an appeal under Sec. 405.450.
In Sec. 405.415(o), we propose that a private contract must be
entered into for each opt-out period.
We have been requested to create a standard form for the private
contract. We have decided that such a form is not necessary. While the
minimal content of the contract is controlled by Federal law and
regulation, the contracts are otherwise private agreements. Moreover,
such contracts will not generally be provided to nor inspected by the
Government.
Requirements for Opt-Out Affidavits
In Sec. 405.420, we specify the required elements of the affidavit
that the physician or practitioner must file with Medicare to opt-out.
In Sec. 405.420(a), as required by section 1802(b)(3)(B)(i) of the Act,
we specify that the affidavit must be in writing and be signed by the
physician or practitioner.
In Sec. 405.420(b), we specify that the affidavit must contain the
physician or practitioner's full name, address, telephone number,
national provider identifier (NPI) or billing number if one has been
assigned, uniform provider identification number (UPIN) if one has been
assigned, or, if neither a NPI, billing number nor a UPIN has been
assigned, the physician or practitioner's tax identification number
(TIN). This information is necessary to enable the Medicare carrier to
positively and uniquely identify the opt-out physician or practitioner,
as required by section 1802(b)(3)(B)(i), and to ensure that no Medicare
payment is made to the physician or practitioner or to any party for
the services of the physician or practitioner (except for emergency and
urgent care services), as required by section 1802(b)(1)(B)of the Act.
Medicare carriers will provide the identifying information to
Medicare+Choice (M+C) plans to ensure that they do not pay opt-out
physicians or practitioners or enable them to be paid by Medicare funds
for services they furnish to Medicare beneficiaries.
The TIN is necessary for physicians and practitioners that do not
have a NPI, billing number, or UPIN so that the carrier can establish a
means of tracking them without forcing them to complete the full
Medicare enrollment process in order to opt-out of Medicare.
Recent data indicate that approximately 4 percent of physicians in
the nation do not provide services to Medicare beneficiaries. We
believe that some of these physicians (and some practitioners who are
currently not enrolled in Medicare) are likely to choose to privately
contract with Medicare beneficiaries under section 1802(b) of the Act,
since doing so will open a market to them. It is also likely that many
of these physicians and practitioners do not have Medicare billing
numbers or UPINs because they have not been providing care to Medicare
beneficiaries. Now, however, if such physicians and practitioners wish
to privately contract with Medicare beneficiaries under section 1802 of
the Act, they will need to be enumerated, for purposes of monitoring
compliance with the law and particularly in case they furnish emergency
or urgent care services for which they must bill and be paid by
Medicare, notwithstanding that they have opted-out. Since we expect the
provision of emergency or urgent care services by opt-out physicians to
be very infrequent, and since we intend to monitor for potential abuse,
we believe that the burden associated with collecting this information
is very slight, is far outweighed by the benefit to beneficiaries of
having these physicians available to provide emergency or urgent care
services if they need such care, and is necessary to monitor
compliance.
In Sec. 405.420(c), we specify, pursuant to sections 1802(b)(3)(A),
1802(b)(3)(B), and 1802(b)(3)(C) of the Act, that the affidavit must
state that the physician or practitioner will provide items and
services to Medicare beneficiaries only through private contracts that
meet the criteria of Sec. 405.415.
In Sec. 405.420(d), we specify that, in accordance with section
1802(b)(3)(B)(ii) of the Act, the affidavit must state that the
physician or practitioner will not submit a claim to Medicare for any
item or service furnished to a Medicare beneficiary, nor will the
physician or practitioner permit any entity acting on his or her behalf
to submit a claim to Medicare for any item or service furnished to a
Medicare beneficiary. The extension of the requirement to include any
``entity'' reflects our belief that very few physicians and
practitioners themselves submit claims for services. Rather, we believe
that most physicians and practitioners use a billing service or
reassign benefits to organizations that bill and are paid for the
physician's or practitioner's services.
In Sec. 405.420(e), we specify that, in accordance with section
1802(b)(3)(B)(ii) of the Act, the affidavit must state that the
physician or practitioner understands that he or she may receive no
direct or indirect payment from Medicare for services to Medicare
beneficiaries who have signed
[[Page 30851]]
private contracts, whether as an employee of an organization, a partner
in a partnership, under a reassignment of benefits, or as payment for a
service furnished to a Medicare beneficiary under a M+C plan. As with
the prohibition on billing, this provision reflects the reality that
most physician and practitioner services are billed by and paid to
organizations to whom the physician or practitioner reassigns benefits.
When a physician or practitioner opts-out of Medicare, no payment
may be made for the services of the physician or practitioner,
regardless of whether another entity bills and is paid for those
services. In our experience, physicians and practitioners frequently
fail to understand that organizations to which they have reassigned
benefits are not, under Medicare law, considered to be the entity that
furnishes the service. Therefore, where a physician reassigns benefits
to an organization and subsequently decides to opt-out of Medicare, he
or she no longer has any Medicare benefits to reassign and that
organization can no longer bill and be paid by Medicare for the
services of the physician or practitioner. This has been a source of
confusion for physicians and practitioners since the implementation of
the private contracting provisions on January 1, 1998, and has resulted
in some physicians being terminated by organizations that can no longer
bill and be paid by Medicare for their services. Hence, we believe that
this important information should be placed in a document that the
physician or practitioner must sign before opting-out.
Moreover, we believe that it is important the physicians and
practitioners understand that opting-out of Medicare means that they
cannot be paid by a Medicare risk or cost contractor or, after June 1,
1998, a M+C organization (for example, an HMO, provider service
organizations, M+C fee for service plans, etc.), since payment by these
organizations for services to Medicare beneficiaries would constitute
payment by Medicare and would be a violation of the private contracting
rules.
In Sec. 405.420(f), as required by section 1802(b)(3)(B)(ii) of the
Act, the affidavit must state that the physician or practitioner
acknowledges that the services provided by the physician or
practitioner who opts-out of Medicare are not covered by Medicare and
that no Medicare payment may be made to any entity for those services,
directly or on a capitated basis. This is important to note since, when
Medicare does not cover a service, it neither pays for the item or
service as primary payer nor makes secondary payment when other
insurers are primary. (Also, many other insurers will not make any
payment because the service is not covered by Medicare.)
In Sec. 405.420(g), we specify that the affidavit must bind the
physician or practitioner to the terms of both the affidavit and the
private contracts for the 2-year opt-out period. Section
1802(b)(3)(B)(ii) of the Act requires that the physician or
practitioner may opt-out for a period of not less than 2 years.
Accordingly, we have defined the opt-out period to be 2 years and have
tied the duration of the private contract to the opt-out period.
In Sec. 405.420(h), we propose that the affidavit must acknowledge
that the physician or practitioner recognizes that the terms of the
affidavit apply to all Medicare-covered items and services furnished by
the physician or practitioner to Medicare beneficiaries, regardless of
any payment arrangement in which the physician or practitioner
participates. It is not unusual for physicians and practitioners to
have multiple sources of income and to reassign benefits to multiple
entities (for example, multiple HMOs, preferred provider organizations,
private practice, and part time employment by a facility). When a
physician or practitioner opts-out, we want to ensure that he or she
understands that he or she opts-out for all Medicare-covered items and
services, regardless of where or on whose behalf they are provided. For
example, a physician who is employed by a facility and who also has a
private practice cannot opt-out of Medicare with respect to only the
private practice and not opt-out for services he furnishes on behalf of
a facility or other organization for which such services are billed to
a carrier and paid under Part B. If the physician opts-out, no Medicare
payment can be made either to the private practice or to the facility
or other organization for the services of the physician. However, if
the physician is paid by the facility for administrative functions
which are not billable to individual beneficiaries as physician
services, such as direction of a department of a hospital or
administrative oversight of a teaching program, the payment by the
facility to the physician is not affected.
In Sec. 405.420(i), we propose that the affidavit must acknowledge
that the physician or practitioner who has previously signed a Part B
participation agreement understands that he or she terminates that
agreement as of the effective date of the affidavit. We believe that
this is necessary to ensure that the physician or practitioner
understands that he or she is no longer a Medicare-participating
physician or practitioner. This is important with regard to post opt-
out billing for emergency and urgent care services. The physician or
practitioner who provides such care (for which Medicare will pay) will
be paid as a nonparticipating physician if he or she submits those
claims for payment, notwithstanding that he or she had a Part B
participation agreement before he or she opted-out.
In Sec. 405.420(j), we specify that the affidavit must acknowledge
that the physician or practitioner understands that a beneficiary who
has not signed a private contract and who requires emergency or urgent
care services may not be asked to sign a private contract with respect
to receiving those services. If a physician or practitioner who opts
out of Medicare provides emergency or urgent care services to a
beneficiary who has not previously signed a private contract, the
physician or practitioner must submit a claim to Medicare for those
services and may not charge the beneficiary more than the limiting
charge for those services.
In Sec. 405.420(k), we propose that the affidavit must be filed
with each Medicare carrier to which the physician or practitioner has
submitted claims in the previous 2 years. This is necessary to ensure
that each Medicare claims payment system that needs to know of the opt-
out is advised promptly so that no Medicare payment is made for the
services of the opt-out physician or practitioner. This is based on
sections 1802(b)(1)(B) and 1802(b)(3)(B)(iii) of the Act.
In Sec. 405.420(l), we specify that in the case of a
nonparticipating physician or a practitioner, all required affidavits
must be filed within 10 days after the physician or practitioner signs
his or her first private contract with a Medicare beneficiary. In the
case of a participating physician, we specify that all required
affidavits must be filed in accordance with Sec. 405.410(d), which
requires that the affidavits be filed no later than 30 days before the
beginning of a calender quarter and must be effective on the first day
of the calender quarter. Section 1802(b)(3)(B)(iii) of the Act requires
that the physician or practitioner file the affidavit within 10 days
after the physician or practitioner signs his or her first private
contract with a Medicare beneficiary. As discussed previously in this
preamble, participating physicians are permitted to opt-out only on a
quarterly basis because of the systems changes that must be made to
reverse the effect of the participation agreements they previously
entered into.
[[Page 30852]]
Various members of the public have requested we create a standard
affidavit for submission to the Medicare carrier. We do not see a
reason to do this. The criteria of a legally sufficient affidavit will
be clearly specified in regulations, and we are confident that
physicians and practitioners and their counsel can produce an affidavit
without needing a Government form to sign.
Effect of Opting-Out of Medicare
In section Sec. 405.425, we specify the effects of opting-out of
Medicare. Specifically, we state that, a physician's or practitioner's
opt-out of Medicare, for the 2-year period for which the opt-out is
effective, has the following effects:
<bullet> In Sec. 405.425(a), we state that (except as provided in
Sec. 405.440), in accordance with section 1802(b)(1)(B) of the Act, no
payment may be made directly by Medicare or by any M+C plan to the
physician or practitioner or to any entity to which the physician or
practitioner reassigns his or her right to receive payment for
services.
<bullet> In Sec. 405.425(b), we state that, in accord with section
1802(b)(3)(B)(ii) of the Act, the physician or practitioner may not
furnish any item or service that would otherwise be covered by Medicare
(except for emergency or urgent care services) to any Medicare
beneficiary except through a private contract that meets the
requirements of these rules.
<bullet> In Sec. 405.425(c), we state that the physician or
practitioner is not subject to the requirement to submit a claim for
items or services furnished to a Medicare beneficiary (as specified in
Sec. 424.5(a)(6)), except as provided in Sec. 405.440 with respect to
emergency and urgent care services.
<bullet> In Sec. 405.425(d), in accordance with section
1802(b)(3)(B)(ii) of the Act, we state that the physician or
practitioner is prohibited from submitting a claim to Medicare for
items or services furnished to a Medicare beneficiary, except as
provided in Sec. 405.440 in the case of emergency or urgent care
services.
<bullet> In Sec. 405.425(e), we state that, in accordance with
1802(b)(4) of the Act, the physician who has properly opted-out is not
subject to the limiting charge provisions of Sec. 414.48.
<bullet> In Sec. 405.425(f), we state that a physician or
practitioner who has properly opted-out is not subject to the
prohibition-on-reassignment provisions of Sec. 414.80. These are the
rules that restrict when physicians and practitioners can reassign
Medicare benefits to organizations with which they have financial
arrangements.
<bullet> In Sec. 405.425(g), we propose that in the case of a
practitioner, he or she is not prohibited from billing or collecting
amounts from beneficiaries in excess of those provided in section
1842(b)(18)(B) of the Act. This is not specifically provided for by
section 4507 of BBA 1997; however, we believe that this provision is
consistent with sections 1802(b)(1) and (2)(B) of the Act, that, when
read together, permit practitioners to collect more than the deductible
and coinsurance to which they are limited under section 1842(b)(18)(B)
of the Act when they provide covered services to Medicare beneficiaries
under standard Medicare rules. Section 1842(b)(18)(B) of the Act
specifies that practitioners must take assignment on all claims and may
not collect more than Medicare deductibles and coinsurance from
Medicare beneficiaries. We believe that the private contracting
provisions exempt practitioners from these restrictions.
<bullet> In Sec. 405.425(h), we propose that the death of a
beneficiary who (or whose legal representative) has entered into a
private contract does not invoke Sec. 424.62 or Sec. 424.64 with
respect to the physician or practitioner with whom the beneficiary (or
legal representative) has privately contracted. These sections of the
regulations permit claims to be filed and payment to be made for
services furnished to a beneficiary who has died. We propose to include
this section to ensure that it is clear that the terms of a private
contract are not superseded by the provisions of Sec. 424.62 or
Sec. 424.64.
<bullet> In Sec. 405.425(i), we specify that the opt-out physician
or practitioner may make referrals and may order or certify the need
for Medicare-covered items and services provided the physician or
practitioner is not paid directly or indirectly by Medicare for those
services. A physician or practitioner who has properly opted-out may
continue to act as a physician or practitioner for purposes of ordering
Medicare-covered services (for example, laboratory tests), making
necessary certifications (for example, home health plan of care),
attestations (for example, hospital inpatient), etc., as long as he or
she is not being paid directly or indirectly by Medicare for these
services.
Failure to Properly Opt-Out
In Sec. 405.430(a), we specify that a physician or practitioner
fails to properly opt-out if any private contract between the physician
or practitioner and a Medicare beneficiary does not meet the standards
of Sec. 405.415 or if the physician or practitioner fails to submit
affidavit(s) in accordance with Sec. 405.420. Sections 1802(b)(2) and
1802(b)(3) of the Act specify the criteria that private contracts and
affidavits must meet in order for the physician or practitioner to
successfully opt-out of Medicare.
In section Sec. 405.430(b), we specify that if a physician or
practitioner fails to properly opt-out as specified in Sec. 405.430(a),
the following result:
<bullet> All of the private contracts between the physician or
practitioner and Medicare beneficiaries are deemed null and void.
<bullet> The physician's or practitioner's attempt to opt-out of
Medicare is nullified.
<bullet> The physician or practitioner must submit claims to
Medicare for all Medicare-covered items and services furnished to
Medicare beneficiaries. Section 1802(b)(4) of the Act, which would
excuse the physician and practitioner from the mandatory claims
submission requirements of section 1848(g)(4) of the Act, is not
effective when the opt-out rules are not met.
<bullet> The physician is subject to the limiting charge provisions
of Sec. 414.48. Sections 1802(b)(1) and 1802(b)(2)(B)(iii), which
excuse the physician from the limiting charge rules, do not apply and
he or she continues to be subject to the limiting charge rules of
section 1848(g) of the Act.
<bullet> The physician or practitioner may not reassign any claim
except as provided in Sec. 424.80. Medicare payment may be made only to
the beneficiary, to the physician or practitioner under an assignment
of benefits or to another party for the services of a physician or
practitioner only when the requirements of the reassignment of benefits
provision of Sec. 424.80 are met.
<bullet> The practitioner may neither bill nor collect an amount
from the beneficiary except for applicable deductible and coinsurance
amounts. Section 1842(b)(18)(B) of the Act explicitly prohibits
practitioners from collecting more than the deductible or coinsurance
from the beneficiary. While this requirement would not apply if the
requirements to properly opt-out had been satisfied, it does apply when
the criteria to properly opt-out have not been met.
<bullet> The physician or practitioner may attempt to properly opt-
out at any time. The statute does not preclude a physician or
practitioner who has not complied totally with the statute's criteria
for opting-out of Medicare from subsequently meeting the criteria and
thus at that time properly opting-out.
Failure to Maintain Opt-out
In Sec. 405.435(a), we specify four circumstances, under any one of
which
[[Page 30853]]
the physician or practitioner would be considered to have failed to
maintain opt-out, that is, failed to remain in compliance with the
requirements of these rules. Specifically, in Sec. 405.435(a)(1), we
state that a physician or practitioner would be considered to have
failed to maintain the opt-out if he or she knowingly and willfully
submits a claim for Medicare payment (except a claim for emergency care
services or urgent care services) or receives Medicare payment directly
or indirectly for services furnished to a Medicare beneficiary (except
when the services are emergency care services or urgent care services).
This implements section 1802(b)(3)(C) of the Act.
In Sec. 405.435(a)(2), we state that the physician or practitioner
would be considered to have violated the terms of the opt-out if he or
she enters into private contracts with Medicare beneficiaries for the
purpose of furnishing items and services that would otherwise be
covered by Medicare when the contracts fail to meet the requirements of
Sec. 405.415. This implements section 1802(b)(2) of the Act that
requires that the physician or practitioner must enter into private
contracts that meet certain criteria for the opt-out to be valid. This
provision is also consistent with the enforcement provisions of section
1802(b)(3)(C) of the Act.
In addition, in Sec. 405.435(a)(3), we specify that the physician
or practitioner would be considered to have failed to maintain the opt-
out if he or she fails to comply with the provisions of Sec. 405.440
regarding billing for emergency care services or urgent care services.
In part, this provision implements section 1802(b)(2)(A)(iii) of the
Act that prohibits a physician or practitioner from requesting that a
beneficiary enter into a private contract when he or she is in need of
emergency or urgent care services and is otherwise necessary to ensure
access by Medicare beneficiaries to emergency and urgent care services.
In Sec. 405.435(a)(4), we propose that the physician or
practitioner would be considered to have failed to maintain opt-out if
he or she fails to retain a copy of each private contract that he or
she entered into for the duration of the opt-out period for which such
contracts are applicable or fails to permit us to inspect such
contracts upon request. The issue of retaining copies of private
contracts is discussed in Sec. 405.415, requirements of the private
contract.
We intend to continue the administrative process currently in place
for dealing with the submission of claims by physicians and
practitioners who have opted-out of Medicare. Specifically, we have
instructed carriers to pend claims they receive from physicians and
practitioners who have filed an affidavit opting-out of Medicare and to
send the physician or practitioner a letter asking him or her if the
submission of the claim was intentional or accidental, and if the
latter by what date the physician or practitioner can remedy the
problem. We recognize that most physicians and practitioners may be
somewhat distant from the billing of their claims and that the use of
automation and billing services increases the chance that one or more
claims may be accidentally submitted to Medicare for an opt-out
physician or practitioner. We also recognize that if the problem is
systematic, it may take some time to correct. Hence, under the current
process, we give physicians and practitioners 45 days from the date of
the postmark on the carrier's letter to respond to the carrier and to
advise them of when they believe the problem can be fixed. Carrier
notices to beneficiaries will advise them that no payment can be made
for the services of the opt-out physician, and that there are no limits
on what the physician or practitioner can charge the beneficiary,
unless the physician or practitioner does not respond timely to the
carrier's letter, does not timely correct the billing problem, or
states that the submission of the claim was intentional. We do not
believe that any of these scenarios will happen often since physicians
and practitioner who opt-out of Medicare clearly have an incentive to
ensure that they abide by the terms of the opt-out and that neither
they nor any party on their behalf submit claims to Medicare.
In section Sec. 405.435(b), we specify that the effects of a
physician or practitioner failing to maintain opt-out as specified in
paragraph (a) are as follows:
<bullet> All of the private contracts between the physician or
practitioner and Medicare beneficiaries are deemed null and void.
<bullet> The physician's or practitioner's opt-out of Medicare is
nullified.
<bullet> The physician or practitioner again becomes subject to the
mandatory claims submission rule. Therefore, the physician or
practitioner must submit claims to Medicare for all Medicare-covered
items and services furnished to Medicare beneficiaries.
<bullet> The physician or practitioner will not receive Medicare
payment on such claims for the remainder of the opt-out period. This is
required by section 1802(b)(3)(C)(ii) of the Act.
<bullet> The physician is subject to the limiting charge provisions
of Sec. 414.48. This is required by section 1848(g) of the Act pursuant
to section 1802(b)(3)(C)(i) of the Act.
<bullet> The practitioner may neither bill nor collect an amount
from the beneficiary except for applicable deductible and coinsurance
amounts. This is required by section 1842(b)(18)(B) of the Act pursuant
to section 1802(b)(3)(C)(i) of the Act.
<bullet> The physician or practitioner may not opt-out until the
now-nullified 2-year opt-out period expires. This is necessary to give
meaning to the enforcement provisions specified in section
1802(b)(3)(C) of the Act.
Emergency and Urgent Care Services
In Sec. 405.440, we specify the rules that apply to furnishing and
billing for emergency and urgent care services. Specifically, in
Sec. 405.440(a), we specify that a private contract is not necessary
for a physician or practitioner to furnish emergency care services or
urgent care services to a Medicare beneficiary. Accordingly, a
physician or practitioner will not be determined to have failed to
maintain opt-out if he or she furnishes emergency care services or
urgent care services to a Medicare beneficiary with whom the physician
or practitioner has not entered into a private contract, provided the
physician or practitioner complies with the Medicare billing
requirements with respect to emergency care services or urgent care
services.
In Sec. 405.440(b), we specify that when a physician or
practitioner furnishes emergency care services or urgent care services
to a Medicare beneficiary with whom the physician or practitioner has
not entered into a private contract, the physician or practitioner must
submit a claim to Medicare in accordance with 42 CFR Part 424 and
Medicare instructions issued pursuant to such regulations, including
instructions on coding emergency or urgent care services. Also, we
propose that the physician may collect no more than the Medicare
limiting charge and that the practitioner may collect no more than the
applicable deductible and coinsurance amounts. We specify these
requirements because the physician or practitioner cannot ask a
beneficiary to enter into a private contract when a beneficiary is in
need of emergency or urgent care services. Therefore, when the
beneficiary has not previously signed a private contract, the
beneficiary has not agreed to give up Medicare coverage for the
services of the physician or practitioner and the services are not
excluded from coverage under Medicare, nor is the physician or
[[Page 30854]]
practitioner excluded from the mandatory claims submission and charge
rules that would not apply had he or she been able to sign a private
contract with the beneficiary.
In Sec. 405.440(c), we specify that emergency care services or
urgent care services furnished to a Medicare beneficiary with whom the
physician or practitioner has previously entered into a private
contract (that is, entered into before the onset of the emergency
medical condition or urgent medical condition) are furnished under the
terms of the private contract. Although section 1802(b)(2)(A)(iii) of
the Act precludes the physician or practitioner from entering into a
private contract with a beneficiary when the beneficiary needs
emergency or urgent care services, the private contracting rules apply
to a beneficiary who has previously entered into a private contract (at
a time when the beneficiary was not in need of emergency or urgent care
services).
In Sec. 405.440(d), we specify that Medicare may make payment for
the emergency care services or urgent care services furnished by a
physician or practitioner who has properly opted-out, provided that no
private contract has been entered into by the beneficiary to whom
emergency care services or urgent care services were furnished.
Although the statute does not explicitly address whether payment may be
made in these cases, we believe that it is both permissible and
desirable to do so since this provision will facilitate access to
needed care in the circumstance when the beneficiary or their legal
representative has not signed a private contract and the physician or
practitioner who has opted-out cannot lawfully request that the
beneficiary or their legal representative now do so.
Renewal and Early Termination of Opt-out
In Sec. 405.445, we specify the terms of renewal and early
termination of the opt-out. In Sec. 405.445(a), we specify that a
physician or practitioner may renew his or her opt-out by filing an
affidavit with each carrier to which an affidavit was submitted for the
first opt-out period (as specified in Sec. 405.420) and to each carrier
to which a claim was submitted under Sec. 405.440 during the previous
opt-out period, provided such affidavits are filed within 30 days after
the current opt-out period expires. While section 1802(b)(3)(B)(ii) of
the Act provides that the physician or practitioner opts-out for a
period of 2 years, it does not address renewal of opt-out. Our proposal
is to establish reasonable standards and procedures for the physician
or practitioner to again opt-out of Medicare for subsequent opt-out
periods.
In Sec. 405.445(b), we propose that the physician or practitioner
may terminate the opt-out for any reason within the 90 days following
the effective date of the first affidavit filed with Medicare if he or
she agrees to do the following:
<bullet> Notify all Medicare carriers with which he or she filed
an affidavit to properly opt-out of the termination of the opt-out, no
later than 90 days after the effective date of the opt-out period.
<bullet> Refund to beneficiaries all payment collected in excess
of the Medicare limiting charge, in the case of physicians, or in
excess of the deductible and coinsurance, in the case of practitioners.
<bullet> Notify all beneficiaries with whom the physician or
practitioner signed private contracts of the physician's or
practitioner's decision to terminate opt-out and of the beneficiaries'
right to have the physician or practitioner file claims on their
behalf, without charge, with Medicare for the services furnished during
the period between the effective date of the opt-out and the effective
date of the termination of the opt-out.
In Sec. 405.445(c), we propose that when the physician or
practitioner properly terminates opt-out in accordance with paragraph
(b), he or she will be reinstated in Medicare as if there had been no
opt-out and the provisions of ' 405.425 will not apply for the 2 years
following the signing of the affidavit unless the physician or
practitioner subsequently properly opts-out again.
We recognize that there may be cases when the physician or
practitioner may not have understood the opt-out rules and may want to
return to Medicare. We believe that it is advantageous to all parties
to permit a first-time opt-out physician or practitioner to properly
terminate opt-out. However, we are requiring that to properly terminate
opt-out, the termination must be accomplished within 90 days following
the effective date of the first opt-out, and we are permitting only one
termination of opt-out by the physician or practitioner. We believe
that it would be a mistake to permit repeated terminations of opt-out,
since it could be abused to manipulate payment, could create a
significant expense for Medicare systems, and would be confusing to
beneficiaries.
Appeals
In Sec. 405.450, we propose procedures for appeals by physicians or
practitioners and beneficiaries who believe that they have been
adversely affected by these rules.
In Sec. 405.450(a), we address appeals of determinations by
Medicare that a physician or practitioner has failed to properly opt-
out, failed to maintain opt-out, failed to timely renew opt-out, failed
to privately contract, or failed to properly terminate opt-out by
proposing that a determination with respect to any such matter is an
initial determination for purposes of Sec. 405.803. The effect of this
provision is that the appeals mechanism found in Part 405, Subpart H is
made available to physicians or practitioners for the purpose of
administrative review of Medicare determinations on matters addressed
in this subpart. Although we believe that these procedures will rarely
be needed for this purpose, we believe that it is important to provide
this mechanism because of the potential adverse impact on the physician
or practitioner of any such determination.
In Sec. 405.450(b), we propose that a determination by Medicare
that no payment can be made to the beneficiary as a result of the
application of any provision of this subpart is a initial determination
for the purposes of Sec. 405.803. We believe that the beneficiary must
have the right to appeal a denial of Medicare payment on a claim
submitted by or on behalf of the beneficiary when the basis for that
denial is the application of the provisions of this subpart. The effect
of this provision is that the appeals mechanism of Part 405, Subpart H
is made available to beneficiaries whose claims for Medicare payment
are denied on the basis of the opt-out provisions of this rule.
Under the BBA 1997 requirements, the physician who opts out under
these provisions must sign an affidavit agreeing for 2 years not to
furnish services to any Medicare beneficiary without signing a private
contract. We expect that the vast majority of opt-out physicians will
fully comply with these terms. Although we expect that physicians will
tell beneficiaries that they have opted-out, we are concerned that
there may be cases when an opt-out physician delivers non-emergency or
non-urgent services to a beneficiary without entering into a private
contract. The beneficiary may be unaware that the physician has opted
out. Nevertheless, the beneficiary would be billed for the physician's
full charges for the service. If the beneficiary seeks reimbursement
from Medicare, the claim would be denied and the beneficiary would be
informed that the reason for denial is that the physician has opted-out
of the Medicare program. We do not believe that the Congress intended
that beneficiaries who have
[[Page 30855]]
not chosen to sign a private contract would be financially harmed
because they unknowingly received services from an opt-out physician.
While the statute does not provide a specific remedy for this situation
and we expect the physician will tell beneficiaries that they have
opted-out, we believe that we have authority to develop some
beneficiary protections in this case in the limited cases when
physicians do not do so. One possibility would be to indemnify the
beneficiary for the amount that Medicare would have normally paid,
ensuring that the beneficiary is informed that the physician is an opt-
out physician. The program would then recoup this amount from the
physician and the physician would refund to the beneficiary any
balanced billing amounts above Medicare's limiting charge. The
beneficiary would remain liable for any coinsurance and deductible
amounts that would have been paid in the absence of a private contract.
A means of informing beneficiaries enrolled in M+C organizations may be
to require that such organizations disclose information on opt-out
physicians upon request by the beneficiary. We would welcome comments
on these and other approaches to providing protection for beneficiaries
in these circumstances.
Medicare+Choice
In Sec. 405.455, we propose to specify the requirements that are to
be imposed on an organization that has a contract with us to provide
one or more M+C plans to beneficiaries (Part 422 of this chapter). The
location of this section may change to part 422 with the final rule,
once the M+C interim rules are published. Part 422 will be the location
of the regulations that govern Part C of Medicare, commonly known as
M+C.
In Sec. 405.455(a), we propose that the M+C organization must
acquire and maintain information from Medicare carriers on physicians
and practitioners who have opted-out of Medicare.
In Sec. 405.455(b), we specify that the M+C organization must make
no payment directly or indirectly for Medicare-covered services
furnished to an enrolled Medicare beneficiary by a physician or
practitioner who has opted-out of Medicare. The services of physicians
and practitioners who properly opt-out are excluded from Medicare under
section 1862(a)(19) of the Act. Therefore, no payment may be made for
them as Medicare-covered services.
In Sec. 405.455(c), we specify that M+C organizations may make
payment to a physician or practitioner who has properly opted-out if he
or she furnishes emergency or urgent care services to a beneficiary who
has not previously entered into a private contract with the physician
or practitioner. This is consistent with our policy in Sec. 405.440
where Medicare payment is made by carriers rather than through M+C
contracts.
C. Payment for Outpatient Rehabilitation Services
The term outpatient rehabilitation therapy encompasses outpatient
physical therapy (including speech-language pathology) and outpatient
occupational therapy.
1. Overview of Policies Before BBA 1997
a. Coverage. Section 1861(p) of the Act defines outpatient physical
therapy services as physical therapy services furnished to a
beneficiary as an outpatient who meets the following criteria:
<bullet> Is under the care of a physician.
<bullet> Has a plan of treatment or care established by either a
physician or by a qualified physical therapist.
<bullet> Has the plan of treatment or care periodically reviewed by
a physician.
The statute also incorporates speech language pathology services
within the definition of outpatient physical therapy services.
Section 1861(g) of the Act states that the term ``outpatient
occupational therapy services'' has the same meaning given the term
``outpatient physical therapy services'' in section 1861(p), except
that the word ``occupational'' is substituted for the word ``physical''
each time it is used in section 1861(p).
b. Providers of Outpatient Rehabilitation Services. Outpatient
physical therapy services (including speech-language pathology
services) and outpatient occupational therapy services are furnished by
providers of services, clinics, rehabilitation agencies, public health
agencies, or by others under an arrangement with, and under the
supervision of such entities. As defined in section 1861(w) of the Act,
the term ``arrangements'' is limited to arrangements under which
receipt of payment by the provider discharges the liability of the
beneficiary to pay for services.
Providers that furnish outpatient physical and occupational therapy
services include hospitals, skilled nursing facilities (SNFs),
rehabilitation agencies, home health agencies (HHAs), hospices, and
comprehensive outpatient rehabilitation facilities (CORFs) furnishing
services to patients other than those who receive SNF or inpatient
hospital benefits.
Hospital inpatients who have exhausted their hospital inpatient
benefits and who are entitled to Part B, and SNF patients who have
exhausted their SNF benefits and who are entitled to Part B may receive
outpatient physical therapy services (including speech-language
pathology services) and outpatient occupational therapy services even
though they are inpatients of the provider. Section 1861(p) of the Act
defines outpatient physical therapy services as those services that
meet the requirements of the first sentence of 1861(p), yet that are
furnished to a beneficiary as an inpatient of a hospital or extended
care facility. Section 1861(p) of the Act must be read in conjunction
with section 1833(d) of the Act. The latter section provides that
Medicare Part B payments, such as payment for outpatient physical and
occupational therapy services, may be made only when there is no
eligibility for Medicare Part A payments for the service, such as
payments for inpatient hospital or SNF care. Part B payment may be made
for inpatients only when there is no eligibility for Medicare Part A
payments; this means only a beneficiary who is not entitled to Medicare
Part A benefits or who has exhausted his or her Part A benefits. Also
see Sec. 410.60(b) (Outpatient physical therapy services: Conditions,
Outpatient physical therapy services to certain inpatients of a
hospital or a CAH or SNF).
Outpatient physical therapy (including speech-language pathology)
and occupational therapy services furnished by a home health agency may
be covered as ``medical and other health services'' under section
1861(s) of the Act when the beneficiary is not entitled to receive home
health benefits under section 1814(a)(2)(C) because he or she is not
homebound. To qualify for home health benefits, the beneficiary must be
homebound and need or have needed skilled nursing care on an
intermittent basis or physical or speech therapy, or in the case of an
individual who no longer has need for such care or therapy, continues
to need occupational therapy. Thus, most rehabilitative services
furnished by home health agencies under section 1861(s)(2)(D)
provisions are furnished to beneficiaries who are not homebound.
Section 1861(cc)(1) of the Act defines the services that can be
provided by a CORF. In addition to outpatient rehabilitation services,
CORF services include: physician services; respiratory therapy;
prosthetic and orthotic devices; social and psychological services;
nursing care; drugs and biologicals that cannot be self-administered;
supplies
[[Page 30856]]
and medical equipment; and, such other services as are medically
necessary and are ordinarily furnished by CORFs.
Services furnished by either a qualified physical therapist or a
qualified occupational therapist in his or her office or in the
beneficiary's home, for example, services of a physical therapist in
independent practice (PTIP) or occupational therapist in independent
practice (OTIP), are included as outpatient physical therapy services
and outpatient occupational therapy services. Medicare does not cover
the services of a speech-language pathologist in independent practice.
c. Payment for Services. (1) Reasonable Cost-Based Payments
Outpatient physical, occupational, and speech-language pathology
services furnished by a provider of services, a clinic, a
rehabilitation agency or public health agency are paid based on the
lesser of the charges imposed for the services or the reasonable costs
of providing the services.
The reasonable cost of services furnished under arrangements may
not exceed an amount equivalent to the prevailing salary and additional
costs that would reasonably have been incurred by such provider or
other organization had the services been performed by an employee. See
Sec. 413.106 (Reasonable cost of physical and other therapy services
furnished under arrangements).
The salary equivalency guideline amounts currently in effect were
published as a final rule on January 30, 1998, (63 FR 5106). In that
final rule, we updated the physical and respiratory therapy guideline
amounts and introduced new salary equivalency guidelines for
occupational therapy and speech-language pathology services furnished
under an arrangement. These guideline amounts are effective for
services furnished on or after April 10, 1998. The guidelines are used
by fiscal intermediaries to determine the maximum allowable cost of
those services. In general, the salary equivalency guideline amounts
are comprised of a prevailing hourly salary rate based on the 75th
percentile of the range of salaries paid to full-time employee
therapists by providers in the geographic area, by type of therapy, and
a fringe benefit and expense factor; a standard travel allowance and
additional allowances for costs incurred for services furnished by an
outside supplier.
(2) Fee Schedule Payments. Physical and occupational therapy
services furnished by physicians and certain other recognized
practitioners are payable by the carriers under the physician fee
schedule. This includes services of PTIPs and OTIPs. The fee schedule
also applies to nonphysician practitioners who furnish services that
would be physician services if furnished by a physician. Nonphysician
practitioners include physician assistants (section 1861(s)(2)(K)(i) of
the Act); and nurse practitioners and clinical nurse specialists
(sections 1861(s)(2)(K)(ii) and 1861(s)(2)(K)(iii) of the Act)
operating within the scope of their State licenses and within certain
settings. Physical and occupational therapy services provided incident
to the services of physicians or incident to the services of the
recognized nonphysician practitioners cited above are payable by the
carriers under the physician fee schedule.
d. Financial Limitation. Outpatient physical therapy services
provided by a PTIP and outpatient occupational therapy services
furnished by an OTIP are subject to an annual financial limitation.
This annual limitation or cap is $900 per beneficiary of incurred
expenses for physical therapy services and $900 per beneficiary of
incurred expenses for occupational therapy services. There is a
beneficiary liability that is comprised of the Part B deductible amount
and 20-percent coinsurance. If a beneficiary has already satisfied the
Part B deductible, the maximum amount payable by the Medicare program
under each of these benefits is $720, for example, 80 percent of $900.
The limit on expenses applies only to items and services covered under
the therapy benefit. When a beneficiary exceeds the annual limitation
or cap, the beneficiary is financially liable for any additional
therapy services that are furnished during the calendar year.
2. BBA 1997 Provisions Affecting Payment for Outpatient Rehabilitation
Services
a. Reasonable Cost-Based Payments. Section 4541(a) of BBA 1997
added new section 1834(k) of the Act. Section 1834(k)(2) established a
10 percent reduction in the reasonable cost of therapy services
furnished during 1998. The 10-percent reduction does not apply to
outpatient therapy services furnished by hospitals or critical access
hospitals. In accordance with this provision, we are proposing to make
payment for outpatient rehabilitation services furnished during 1998
based upon the lesser of the charges imposed or the reasonable cost
determined for such services, reduced by 10 percent. The 10-percent
reduction shall not apply to outpatient physical therapy or
occupational therapy services furnished by a hospital to an outpatient
or to a hospital inpatient entitled to benefits under Part A but who
has exhausted benefits or is otherwise not in a covered Part A stay.
The salary equivalency guidelines will continue to remain in effect
until all BBA 1997 provisions regarding a prospective payment system
for outpatient rehabilitation services are implemented. The prospective
payment system will negate the need for salary equivalency guidelines
because providers will no longer be paid on a reasonable cost basis for
their therapy services. The salary equivalency guidelines were a tool
used to determine the reasonable cost of therapy services provided by
practitioners other than physicians.
b. Prospective Payment System for Outpatient Rehabilitation
Services. (1) Overview. Section 4541 of BBA 1997 adds a new section
1834(k) to the Act that provides for a prospective payment system for
outpatient rehabilitation services and all services provided by CORFs.
The prospective payment system is effective for services furnished on
or after January 1, 1999. Section 1834(k)(1)(B) of the Act provides for
payment for those services to be made at 80 percent of the lesser of
(1) the actual charge for the services, or (2) the applicable fee
schedule. Section 1834(k)(3) defines the applicable fee schedule amount
as the amount determined under the physician fee schedule, or, if there
is no such fee schedule established for those services, the amount
determined under the fee schedule established for comparable services
as specified by the Secretary.
The physician fee schedule is currently applied to certain
outpatient rehabilitation therapy services. It is now the basis of
payment for outpatient rehabilitation services furnished by PTIPs and
OTIPs, physicians, and certain nonphysician practitioners or incident
to the services of such physicians or nonphysician practitioners. The
physician fee schedule has been the method of payment for outpatient
rehabilitation therapy services provided by such entities for several
years. Fee schedule payment will now apply when outpatient physical
therapy, occupational therapy, and speech language pathology services
are furnished by rehabilitation agencies, public health agencies,
clinics, SNFs, home health agencies for beneficiaries who are not
eligible for home health benefits because they are not homebound,
hospitals (when such services are provided to an outpatient or to a
hospital inpatient who is entitled to
[[Page 30857]]
benefits under Part A but who has exhausted benefits or is not
entitled), and CORFs. The fee schedule also applies to outpatient
rehabilitation services furnished under an arrangement with any of the
cited entities that are to be paid on the basis of the physician fee
schedule. The fee schedule will not apply to outpatient rehabilitation
services furnished by critical access hospitals. Under section 1833 of
the Act as amended by Section 4541 of BBA 1997, these services will be
paid on a reasonable cost basis.
(2) Services Furnished by Skilled Nursing Facilities. Section
4432(a) of BBA 1997 added a new subsection(e) to section 1888 of the
Act to establish a prospective payment systems for SNFs. Under the
statute, effective for cost reporting periods beginning on or after
July 1, 1998, Medicare pays for covered Part A SNF stays on the basis
of prospectively determined payment rates which encompass all costs of
``covered skilled nursing facility services'' furnished to a SNF
resident. The statute defines covered SNF services to include (1) post-
hospital extended care services paid for under Part A, as well as (2)
certain services that may be paid under Part B and which are furnished
to SNF residents receiving covered post-hospital extended care
services. Section 1888(e)(2) provides for exclusion of specific
services from the definition of covered SNF services, but the statute
explicitly states that the exclusions do not encompass ``any physical,
occupational or speech language therapy services regardless of whether
or not the services are furnished by, or under the supervision of, a
physician or other health care professional.'' Thus, if a SNF resident
is in a covered Part A stay, therapy services furnished to the SNF
resident are encompassed in the PPS payment and Medicare does not make
a separate Part B payment.
Under the new payment system for SNF inpatient services, and
consistent with current policy (which applied before enactment of BBA
1997, services furnished to SNF residents that are not covered under
Part A may nevertheless be covered under Part B. Section 4432(b) of BBA
1997 amended section 1842(b)(6) of the Act to require that payment for
most services furnished to an individual who is a resident of a SNF,
including outpatient rehabilitation services, be made to the facility
(without regard to whether the service was furnished by the facility,
by others under arrangement with the facility, or under any other
arrangement). When the services are not being furnished directly, the
facility then pays the provider of therapy services. The consolidated
billing provision is effective for services furnished on or after July
1, 1998.
Section 4432(b)(3) of BBA 1997 added a new paragraph (9) to section
1888(e) of the Act to provide that, with respect to a service covered
under Part B that is furnished to a SNF resident, the amount of payment
for the service shall be the amount provided under the fee schedule for
such item or service. This provision must be read in conjunction with
the provisions of section 4541 of BBA 1997. Section 4541 added a new
section 1833(a)(8) to specify that the amounts payable for outpatient
rehabilitation services furnished by a SNF will be the amounts
determined under section 1834(k) of the Act. Section 1834(k) of the Act
provides that payment in 1998 shall be based on adjusted reasonable
costs and in 1999 and thereafter, the physician fee schedule. Thus, we
are proposing that SNF Part B inpatient services remain payable on a
reasonable cost basis until January 1, 1999. Effective January 1, 1999,
the services will be paid under the physician fee schedule.
The physician fee schedule amount applicable to services furnished
in a non-facility setting will apply to the Part B services to
inpatients and other outpatient rehabilitation services furnished by
the SNF. The non-facility amount applies because the consolidated
billing provision requires that the SNF be directly paid for the entire
therapy service (including facility costs) based on the physician fee
schedule. This is in contrast to the amount applicable to physician
services, excluding outpatient rehabilitation services, billed for SNF
residents. In this case, the physician payment is not intended to cover
the facility costs associated with the service and the fee schedule
amount applicable to services furnished in a facility applies.
(3) Services Furnished by Home Health Agencies. Section
1833(a)(8)(A) requires that the physician fee schedule applies to
outpatient rehabilitation services furnished by a HHA to an individual
who is not homebound. The likelihood is great that most individuals who
are homebound and are receiving physical therapy, speech-language
pathology, or occupational therapy are entitled to home health
benefits. Therefore, most outpatient rehabilitation services furnished
by a HHA under section 1861(s)(2)(D) is to individuals who are not
homebound. There may be, however, some individuals who are not
homebound and have not required a qualifying service for home health
benefits but who need occupational therapy services. If provided by a
HHA, these services could be provided under section 1861(s)(2)(D) of
the Act. Since section 4541 of BBA 1997 did not expressly address these
services, they remain payable on a reasonable cost basis under section
1861(v)(1) of the Act. All other services furnished by the HHA will be
paid under a prospective payment system (effective October 1, 1999 with
respect to home health services). Section 1861(v)(1) provides that the
reasonable cost of any service shall be the cost actually incurred,
excluding any costs unnecessary to the efficient delivery of needed
health services. Since all other outpatient rehabilitation services are
to be paid under the physician fee schedule, we believe it would be
unreasonable for the costs of the services furnished to homebound
beneficiaries who are not entitled to home health benefits to exceed
the amount payable under the physician fee schedule. Therefore, we are
proposing to modify Sec. 413.125 to provide that effective for services
furnished on or after January 1, 1999, the reasonable cost of
outpatient rehabilitation services furnished by a HHA to homebound
patients who are not entitled to home health benefits may not exceed
the amounts payable under the physician fee schedule.
(4) Services Furnished by Comprehensive Outpatient Rehabilitation
Facilities. Section 4541(a)(1) adds a new section 1832(a)(2)(D)(9) of
the Act to provide that all services furnished by a CORF, and not just
outpatient rehabilitation services, will be paid the applicable fee
schedule amount. In cases where there is no physician fee schedule
amount for the services, section 1834(k) specifies that the applicable
fee schedule amount will be the amount established for comparable
services as specified by the Secretary. Therefore, we are proposing
that the existing fee schedules for prosthetic and orthotic devices,
durable medical equipment, and supplies, and drugs and biologicals
apply when these services are furnished by a CORF. We believe that
these fee schedules, together with the physician fee schedule, will
encompass all CORF services other than nursing services. The physician
fee schedule amount applicable to services furnished in a non-facility
setting will apply to the services furnished by the CORF since no
separate payment will be made for facility costs.
To establish a fee schedule amount for nursing services delivered
within a CORF, we created a new HCPCS code, G0128. We are defining this
code as
[[Page 30858]]
direct face-to-face skilled nursing services delivered to a CORF
patient as part of a rehabilitative plan of care. It is a timed code
and can be billed for 10-minute intervals (when the initial interval is
longer than 5 minutes). G0128 is to be used for services that are not
included in the work or practice expense of another therapy or
physician service. An example might be a nurse who spends 33 minutes
instructing a patient in the proper procedure of ``in and out''
urethral catheterization; in this situation, 3 units of G0128 would be
billed. We are proposing to set the RVUs for this code at 0.26, based
upon half the value of the lowest level physician follow-up visit,
HCPCS code 99211, in the non-facility setting. This results in a
payment for the time slightly more than the average wage reported by
the Bureau of Labor Statistics (BLS) for RNs, inflated to reflect
benefits and overhead (using the fringe benefit and expense factor used
to establish the salary equivalency guideline).
(5) Site-of-Service Differential. Providers of outpatient
rehabilitation services have suggested that we should consider making a
site-of-service differential, specifically, a payment amount greater
than that provided by the physician fee schedule for some of the types
of providers or sites at which outpatient rehabilitation services are
furnished. We are not proposing such a differential.
First, the law requires that these services be paid the amount
determined ``under the fee schedule established under section 1848.''
Furthermore, we believe higher payment amounts for certain facilities,
such as CORFs or rehabilitation agencies, would create payment
incentives that favor one site or setting over another. We believe the
statute establishes a ``level playing field'' for these services. We
find no direction in the statutory language or legislative history that
we recognize higher costs that some providers argue might be associated
with furnishing services in a provider setting. To the extent that
CORFs or rehabilitation facilities provide services to patients who
need additional care, CORFs or rehabilitation facilities may bill for
additional, medically necessary services. For these reasons, a site of
service adjustment or higher payment amount for specific settings is
not being proposed; however, we welcome any comments that you may
present regarding differences in services furnished in the various
settings that would justify a differential payment.
(6) Mandatory Assignment. Section 1834(k)(6) of the Act, as added
by BBA 1997, establishes a restraint on billing for outpatient
rehabilitation therapy services; that is, this provision requires that
services paid under section 1834(k) of the Act are subject to mandatory
assignment under the same terms applicable to practitioners under
section 1842(b)(18) of the Act. We propose, therefore, in accordance
with this provision to require mandatory assignment for services
provided under the outpatient rehabilitation prospective payment system
by hospitals, SNFs, HHAs, rehabilitation agencies, public health
agencies, clinics, and CORFs. The mandatory assignment provision does
not apply to therapy services furnished by a physician or ``incident
to'' a physician's service or to services furnished by a physical
therapist in private practice or an occupational therapist in private
practice. However, when these services are not furnished on an
assignment-related basis, the limiting charge applies.
3. Uniform Procedure Codes for Outpatient Rehabilitation Services
Section 4541(a)(2) of BBA 1997 added section 1834(k)(5) of the Act.
This new statutory provision requires that claims submitted on or after
April 1, 1998 for outpatient physical therapy services, including
speech language pathology services and outpatient occupational therapy
services, include a code under a uniform coding system that identifies
the services furnished.
The uniform coding requirement is needed to assure proper payment
under the physician fee schedule. Hospitals, SNFs, HHAs (for
individuals who are not eligible for home health services), CORFs, and
outpatient physical therapy providers must use HCPCS codes to report
outpatient rehabilitation services when furnished to their outpatients.
Hospitals and SNFs that provide outpatient rehabilitation services to
their inpatients who are entitled to benefits under Part A but who have
exhausted their benefits for inpatient services during a spell of
illness or to their inpatients who are not entitled to benefits under
Part A are also required to report HCPCS codes.
In March, 1998, we issued a program memorandum AB-98-8 which
described the coding for outpatient rehabilitation services. This
memorandum identifies the HCPCS codes that will be considered to be
outpatient rehabilitation services and specifies how these codes will
be reported on the UB-92. We assigned the various codes to revenue
centers, that is, physical therapy, occupational therapy, and speech-
language pathology, for purposes of applying the financial limitation
described below. Assigning codes to revenue centers was not intended to
limit the scope of practice or range of procedures that could be
furnished by therapists in a particular discipline. We are in the
process of revising AB-98-8 because we intend to implement the
financial limitation by using modifiers, as described below, rather
than assigning the HCPCS codes to revenue centers.
In the program memorandum, we also identify certain HCPCS codes
available for billing by CORFs that are not generally rehabilitation
services, including vaccinations and nursing services.
4. Financial Limitation
Outpatient rehabilitation therapy services are subject to annual
financial limitations or caps commencing January 1, 1999. (The amount
of the current cap is $900.) There will be a $1,500 per beneficiary
annual limitation or cap on incurred expenses for outpatient physical
therapy services including outpatient speech-language pathology
services. A separate $1,500 per beneficiary limitation will apply on
incurred expenses for outpatient occupational therapy services. The
annual limitation does not apply to services furnished directly or
under arrangements by a hospital or critical access hospital to an
outpatient or to an inpatient who is not in a covered Part A stay. The
limitation will apply to outpatient rehabilitation services furnished
by a separately certified hospital-based provider, such as a hospital-
based SNF. The limitation also applies to outpatient rehabilitation
services furnished by a physician or nonphysician practitioner, or
incident to a physician's professional services or to a nonphysician
practitioner's professional services.
As stated above, there is a single $1,500 limitation for outpatient
physical therapy services and outpatient speech-language pathology
services. As amended, section 1833(g) of the Act applies a single
$1,500 limitation to ``physical therapy services of the type described
in section 1861(p).'' Section 1861(p) defines outpatient physical
therapy services and includes speech-language pathology services within
that definition.
Outpatient rehabilitation services are subject to a 20 percent
coinsurance amount. Under the outpatient prospective payment system,
the beneficiary will be responsible for 20 percent of the applicable
fee schedule amounts. The $1,500 limitation is on incurred expenses. If
a beneficiary has already satisfied the Part B deductible, the maximum
amount payable by the
[[Page 30859]]
Medicare program is $1,200, that is, 80 percent of $1,500. Beginning
January 1, 2002, the $1,500 annual limitations or caps will be
increased by the percentage increase in the MEI.
In addition to outpatient physical therapy services and outpatient
occupational therapy services (other than those provided by a
hospital), the limitation applies to physical therapy services
(including speech-language pathology services) and occupational therapy
services ``of such type which are furnished by a physician or as
incident to a physician service.'' As discussed elsewhere in this
document, Medicare covers under certain conditions services performed
by nurse practitioners, clinical nurse specialists, and physician
assistants that would be physicians' services if furnished by a
physician. We are proposing to apply the financial limitation to
therapy services furnished by these nonphysician practitioners since
such therapy services are by definition the same type as are furnished
by physicians. Similarly, we propose to apply the financial limitation
to therapy services furnished incident to these nonphysician
practitioner's services. We have included in Addendum D a listing of
the specific services that we propose would be subject to the
limitation when furnished by a physician or practitioner directly or
incident to their services. Such outpatient rehabilitation services
included in Addendum D furnished either directly or incident to the
services of a physician or practitioner are always subject to the
financial limitation. Other services such as casting, splinting, and
strapping may be used in the treatment of conditions (for example,
fractures or sprains) or as part of the postsurgical treatment or
medical treatment when no other rehabilitation services are delivered.
If the services are delivered by a physical or occupational therapist,
speech-language pathologist, therapy assistant or therapy aide, are
part of a rehabilitation plan of care, or involve services included in
the aforementioned Addendum D, then the services are subject to the
cap. These outpatient rehabilitation services are delineated in
Addendum E and must be identified with a discipline-specific modifier.
Addendum E contains a listing of outpatient rehabilitation therapy
codes. Payment for certain HCPCS codes will be made on a basis other
than the physician fee schedule in hospital outpatient departments.
Other HCPCS codes are considered as CORF services. Further program
instructions will be provided in a forthcoming program memorandum
regarding the use of HCPCS codes for outpatient rehabilitation therapy
services.
With regard to ``incident to'' services, we note that section
4541(b) of BBA 1997 amended section 1862(a) of the Act to require that
outpatient physical therapy service (including speech-language
pathology services) and outpatient occupational therapy services
furnished ``incident to'' a physician's professional services meet the
standards and conditions (other than any licensing requirement
specified by the Secretary) that apply to therapy services furnished by
a therapist. This provision was effective January 1, 1998 and was
implemented through program instructions.
The financial limitations apply only to items and services
furnished by non-hospital providers and therapists under the outpatient
physical therapy (including speech-language pathology) and the
outpatient occupational therapy benefit (section 1861(s)(2)(D) of the
Act) and therapy services furnished by physicians and nonphysician
practitioners or incident to their services. The limitations do not
apply to diagnostic tests covered under section 1861(s)(3) of the Act.
To track the financial limitation or cap, we are proposing to use
modifiers that will be discipline-specific. Many of the services, for
example, physical modalities or therapeutic procedures as described by
HCPCS codes, are commonly delivered by both physical and occupational
therapists. Other services may be delivered by either occupational
therapists or speech-language pathologists. For these services, we
expect the claim to include a modifier which describes the type of
therapist who delivered the service; if the service was not delivered
by a therapist, then the type of therapy plan of care under which the
service is delivered would be specified. If the type of therapy is not
listed in the modifier field, the claim would be rejected and sent to
the provider for resubmission.
As required by section 1833(g) of the Act, as amended by section
4541 of BBA, we propose to establish two annual per beneficiary limits
of $1,500. There will be (1) an annual per beneficiary limit for all
outpatient physical therapy services excluding hospital outpatient
therapy services and (2) an annual per beneficiary limit for all
outpatient occupational therapy services excluding hospital outpatient
therapy services. As stated previously, outpatient physical therapy
services include speech-language pathology services. A provider of
outpatient rehabilitation services with a provider agreement under
section 1866 of the Act as will as physicians, PTIPs and OTIPs will be
allowed to collect payment from a beneficiary for therapy services
after the $1,500 limit is reached. This is consistent with current
policy allowing PTIPs and OTIPs to collect payment from a beneficiary
for therapy services in excess of the current $900 limit.
We note that a report to the Congress is due from the Secretary no
later than January 1, 2001. This report is to include recommendations
on the establishment of a revised coverage policy of outpatient
physical therapy services, including speech-language pathology services
and outpatient occupational therapy services. The revised policy is to
be based on a classification of individuals by diagnosis category and
prior use of services in both inpatient and outpatient settings. The
report should include recommendations on how such durational limits by
diagnostic category could be implemented in a budget-neutral manner.
5. Qualified Therapists
Section 1861(p) includes services furnished an individual by a
physical therapist who meets licensing and other standards prescribed
by the Secretary if the services meet such conditions relating to
health and safety as the Secretary may find necessary. The services
must be furnished in the therapist's office or the individual's home.
By regulation, we have defined therapists meeting the conditions for
coverage of services under this provision as physical therapists in
independent practice. The conditions for coverage are set forth in Part
486, Subpart D (Conditions for coverage: Outpatient Physical Therapy
Services Furnished by Physical Therapists in Independent Practice) and
require that the services be provided by a therapist in independent
practice under Sec. 410.60. Under Sec. 410.60, a therapist in
independent practice is one who:
<bullet> Engages in the practice of therapy on a regular basis.
<bullet> Furnishes services on his or her own responsibility
without the administrative and professional control of an employer.
<bullet> Maintains at his or her own expense office space and
equipment.
<bullet> Furnishes services only in the office or patient's home.
<bullet> Treats individuals who are his or her own patients and
collects fees or other compensation for the services.
Under Sec. 486.151 (Conditions for coverage: Supervision), all
therapy services must be furnished under the direct supervision of a
qualified therapist in independent practice. In
[[Page 30860]]
other words, the therapist in independent practice must be on the
premises whenever services are provided to Medicare beneficiaries,
including services provided by a licensed physical therapist. This
long-standing requirement has been controversial with therapists in
independent practice. For example, a therapist in independent practice
cannot have more than one office open for services at the same time
since he or she could not be on both premises at once.
We are proposing to replace the existing ``Conditions for Coverage:
Outpatient Physical Therapy Services Furnished by Physical Therapists
in Independent Practice'' (Part 486, Subpart D), which requires survey
and certification, with a simplified criteria for physical therapists
in private practice that would use a carrier enrollment process. The
impetus for this change comes from congressional statements associated
with the fiscal year 1997 appropriations process. Statements in both
the House and Senate committee reports accompanying HCFA's fiscal year
1997 appropriations addressed the issue of requiring that the certified
physical or occupational therapist in independent practice directly
supervise all services performed by his or her employees, even if those
employees are fully licensed therapists. The House committee report
urged that we modify the regulations so that the certified therapist
need not be on premises to supervise other licensed therapists. The
Senate urged us to review this concern and recommend regulatory or
instructional changes.
We are proposing to redefine those therapists who are qualified
pursuant to section 1861(p) of the Act. That is, we would discontinue
the focus of the regulation on their ``independent'' status (which is
not statutory) and recognize therapists in private practice who are
employed by others and therefore, do not meet our current
``independent'' criteria. This would be consistent with health and
safety concerns and would conform to normal private sector practice
standards. The following new requirements would replace the current
ones for qualified therapists:
<bullet> The term ``independent'' would be dropped and the benefit
would be for an individual physical therapist or occupational therapist
in private practice.
Private practice would include an ``individual'' whose practice is
in an unincorporated solo practice, unincorporated partnership, or
unincorporated group practice. Private practice also would include an
``individual'' who is practicing therapy as an employee of one of the
above or of a professional corporation or other incorporated therapy
practice. However, private practice would not include individuals when
they are working as employees of a provider. A provider as defined in
Sec. 400.202 includes a hospital, CAH, SNF, HHA, hospice, CORF, CMHC,
or an organization qualified under Part 485, Subpart H (Conditions of
Participation for Clinics, Rehabilitation Agencies, and Public Health
Agencies as Providers of Outpatient Physical Therapy and Speech-
Language Pathology Services), as a clinic, rehabilitation agency, or
public health agency.
<bullet> In implementing the statutory requirement that services be
furnished to an individual in the therapist's office, or in the
individual's home, ``in his office'' would be defined as the
location(s) where the practice is operated, in the State(s) where the
therapist (and practice, if applicable) is legally authorized to
furnish services, during the hours that the therapist engages in
practice at that location.
A therapist in private practice would not be required to maintain a
private office, if services always are furnished in patients' homes.
However, when services are furnished in private practice office space,
that space would have to be owned, leased, or rented by the practice
and used for the exclusive purpose of operating the practice. For
example, because of the statutory restriction on the site of services,
a therapist in private practice cannot furnish covered services in a
SNF. Therefore, if a therapist wished to locate his or her own private
office on site at a nursing facility, special care would need to be
taken. The private office space could not be part of the Medicare-
participating SNF's space, and the therapist's services could be
furnished only within that private office space. Neither the therapist
nor any assistants or aides who help render services could be employed
by the SNF during the same hours that they are working in the private
practice. Another example where special attention would be needed is
space that generally serves other purposes and is only used by a
therapy practice during limited hours. For example, a therapist in
private practice may furnish aquatic therapy in a community center pool
on Wednesday mornings. The practice would have to rent or lease the
pool for those hours, and the use of the pool during that time would
have to be restricted to the therapist's patients, in order to
recognize the pool as part of the therapist's own private office during
those hours.
In describing other services that are specifically limited to the
patient's home, the statute uses qualifying language. For example, the
durable medical equipment definition in section 1861(n) refers to a
patient's home as ``including an institution used as his home other
than an institution that meets the requirements of subsection (e)(1) of
this section or section 1819(a)(1).'' This definition of home is
codified at Sec. 410.38(b). The same definition always has been used in
the Medicare Carriers Manual for purposes of covering therapists'
services in a patient's home. We propose to continue the current
practice and to adopt that definition formally in this regulation.
<bullet> Assistants and aides would have to be personally
supervised by the therapist and employed directly by the therapist, by
the partnership or group to which the therapist belongs, or by the same
private practice that employs the therapist. Personal supervision
requires that the therapist be in the room during the performance of
the service. Levels of supervision are defined in Sec. 410.32.
<bullet> The therapist must be licensed or otherwise legally
authorized to engage in private practice. We understand that all States
license or certify physical therapists, so no alternative personnel
qualifications need to be specified.
<bullet> Each therapist would enroll ``as an individual'' with the
carrier.
There would be no survey and no certification by HCFA. The Medicare
carrier would verify that the qualifications proposed in
Sec. 410.59(c)(1) or Sec. 410.60(c)(1) are met. All applicants for new
enrollment would become subject to these new rules and procedures upon
the effective date of the final rule. For transition purposes, we
intend that independent therapists who are certified and enrolled at
that time would be ``grandfathered'' temporarily and would become
subject to the new enrollment rules and procedures at the time of their
next regular periodic reenrollment.
These changes would address the concern that current rules require
each independent therapist to personally supervise services performed
by any other licensed therapists that he or she employs. Under our
proposal, each individual therapist in a practice could qualify to
separately enroll, and enrolled therapists would not be required for
purposes of Medicare to be supervised by their employer. These changes
also address the concern that current rules prohibit an independent
therapist from being employed by any entity. Under our proposal, a
variety of
[[Page 30861]]
employment situations would be permitted. The following examples
illustrate how our proposals would apply:
<bullet> Three PTs operate an unincorporated group practice, which
employs several physical therapy assistants and aides and maintains two
offices in two towns. Each therapist could enroll as a physical
therapist in private practice and could furnish services in either
office, while personally supervising any of the assistants or aides who
are helping to render therapy.
<bullet> A corporation operates a physical therapy practice which
employs four physical therapists and several physical therapy
assistants and aides. Each therapist could enroll as a physical
therapist in private practice and could personally supervise any of the
assistants or aides who help to render therapy. If two additional PTs
are hired, each must enroll before their services could be covered
without supervision by one of the enrolled physical therapists.
A physical therapist works for a hospital's rehabilitation
department during the day. During evening hours, he operates his own
incorporated professional practice and goes to patient's homes to
furnish therapy. He could enroll as a physical therapist in private
practice for the evening hours and would not need to maintain an office
for furnishing therapy.
A physician's professional corporation employs three physical
therapists and six physical therapy assistants in a private therapy
practice associated with the physician's office. Each of the PTs could
enroll as a therapist in private practice. The physician is not
required to supervise any of the therapy. All physical therapy services
for which Medicare payment is sought are supervised by one of the
physical therapists.
These new requirements would be established in a revised
Sec. 410.60(c) for physical therapists. To date, the statutory
requirements for coverage of outpatient occupational therapy services
have not been codified. We are proposing to codify these requirements
by establishing a new Sec. 410.59 for outpatient occupational therapy
services. The proposed regulations section for outpatient occupational
therapy parallels the Sec. 410.60 requirements for outpatient physical
therapy, as revised in this proposed rule. We are also proposing to
make conforming changes in Sec. 410.61 to include occupational therapy.
Therapists in private practice do not participate in the Medicare
program in the same way that ``providers of services'' do. Though they
must be approved as meeting certain requirements, unlike ``providers of
services,'' they do not execute a formal provider agreement with the
Secretary as described in Part 489 (Provider Agreements and Supplier
Approval) of the CFR. Like physicians, they do have the option of
accepting a beneficiary's assignment of his or her claim for Medicare
Part B benefits and of becoming a Medicare participating supplier who
agrees to accept assignment in all cases.
6. Plan of Treatment
We are proposing to revise Secs. 410.61(e), 424.24(c)(4)(i), and
485.711(b), which concern the plan of treatment review requirements for
outpatient rehabilitation therapy services. Section 1861(p) of the Act
defines these therapy services, in part, as services furnished to an
individual who is under the care of a physician and for whom a plan,
prescribing the type, amount, and duration of therapy services that are
to be furnished, has been established by a physician or a qualified
therapist and is periodically reviewed by a physician.
Currently, providers that furnish outpatient rehabilitation therapy
services are required to have a physician review the plan of treatment
and recertify the need for care at least every 30 days. We are
proposing that the physician review and recertify the required plan of
treatment within the first 62 days and at least every 31 days after the
first review and recertification. The current requirement for the
review of a plan of treatment for patients of physical therapists in
independent practice is similar in that the physician must review the
plan at least every 30 days. We are proposing to change this review
requirement as well to require that the physician review and recertify
the plan of treatment within the first 62 days and at least every 31
days thereafter.
We are recommending these changes because it is our understanding
that an initial 2-month (62 day) review is consistent with usual
therapy course of treatment. It is also consistent with our current
therapy requirements in the home health setting. These changes would
reduce the burden on providers, patients, and physicians by eliminating
the current requirement for an initial review within the first 30 days.
After the first 62 days, we believe that patients receiving outpatient
rehabilitation services are likely to show significant progress that
warrants subsequent reviews every 31 days. Changes in the patients'
level of function and need for continued therapy can be expected to
occur more frequently after the first 2 months of therapy. We believe
this subsequent review schedule will help control potential over-
utilization that results in excessive therapy to some Medicare
patients.
Under our proposal, the therapists would be required to immediately
notify the physician of any changes in the patient's condition, and
physicians would retain the ability to review the care at closer
intervals if necessary.
D. Payment for Services of Certain Nonphysician Practitioners and
Services Furnished Incident to Their Professional Services
Nonphysician practitioner services have been covered by Medicare
since the inception of the program; originally the law did not provide
for separate payments for these services. Coverage and payment of
nonphysician services was primarily within the context of section
1861(s)(2)(A) of the Act as implemented by section 2050 of the Medicare
Carriers Manual, for the payment of services incident to a physician's
professional services. In recent years, the Congress has expanded
Medicare coverage of nonphysician practitioner services in certain
settings to improve beneficiary access to medical services. Separate
Part B coverage is specifically authorized for certain nonphysician
practitioner services and for services and supplies furnished as
incident to those services.
For purposes of this proposal as it applies to nonphysician
practitioners, we define nonphysician practitioners as nurse
practitioners, clinical nurse specialists, certified nurse-midwives,
and physician assistants. With respect to services and supplies
furnished as incident to a nonphysician practitioner's services, we are
proposing that to be covered by Medicare, the services must meet the
longstanding requirements in section 2050 of the Medicare Carriers
Manual applicable to services furnished as incident to the professional
services of a physician. Therefore, we would specify, in proposed new
Secs. 410.74(b), 410.75(d), 410.76(d), and 410.77(c) that Medicare Part
B covers services and supplies (including drugs and biologicals that
cannot be self-administered) furnished as incident to the
nonphysician's services only if these services and supplies would be
covered if furnished by a physician or furnished as incident to a
physician's professional services. In addition, Secs. 410.74(b),
410.75(d), 410.76(d), and 410.77(c) would specify
[[Page 30862]]
the various requirements for these incidental services and supplies.
1. Coverage and Payment for Nurse Practitioner Services Before BBA 1997
Effective for services furnished on or after April 1, 1990, section
6114 of the Omnibus Budget Reconciliation Act (OBRA) of 1989 (Pub. L.
101-239) authorized separate payment for the services of nurse
practitioners when furnished to patients in SNFs and nursing
facilities. The services of nurse practitioners are covered if they are
furnished in collaboration with a physician, they are within the scope
of services authorized by State law, and they are the type of services
that would be covered when furnished by a physician. The term,
collaboration is defined as a process in which a nurse practitioner
works with a physician to deliver health care services within the scope
of the practitioner's professional expertise, with medical direction
and appropriate supervision as provided for in jointly developed
guidelines, or other mechanisms as defined by State law, in the State
in which the services are performed.
Section 6114 of OBRA 1989 limited routine visits by nurse
practitioners who are serving as members of a team to 1.5 team visits
per month per resident of a SNF or nursing facility. The team must
include a physician and a physician assistant acting under the
supervision of the physician, or a nurse practitioner or a clinical
nurse specialist working in collaboration with a physician.
Section 6114 of OBRA 1989 requires that payment for nurse
practitioner services furnished to patients in SNFs and nursing
facilities be made on an assignment-related basis to the nurse
practitioner's employer only. This provision also limited the
prevailing charges for the services of nurse practitioners furnished
before January 1, 1992, to 85 percent of the prevailing charge rate
determined for these services when furnished by nonspecialist
physicians. For services furnished on or after January 1, 1992, OBRA
1989 limits the payment to 85 percent of the physician fee schedule
amount for those services furnished by physicians who are not
specialists.
The qualifications for nurse practitioners require individuals to:
<bullet> Be a registered nurse who is currently licensed to
practice in the State where he or she practices, be authorized to
perform the services of a nurse practitioner in accordance with State
law, and have a master's degree in nursing;
<bullet> Be certified as a nurse practitioner by a professional
association recognized by HCFA that has, at a minimum, eligibility
requirements that meet the standards in the paragraph above; or
<bullet> Meet the requirements for a nurse practitioner set forth
in the first paragraph, except for the master's degree requirement, and
have received before 3 years prior to the effective date of a final
rule, a certificate of completion from a formal advanced practice
program that prepares registered nurses to perform an expanded role in
the delivery of primary care.
Section 4155 of OBRA 1990 (Pub. L. 101-508) extended coverage of
nurse practitioner services that was previously restricted to SNFs and
nursing facilities, to all settings in rural areas. Additionally, nurse
practitioners were authorized to either receive direct payment or
arrange for payment to be made directly to their employer for services
furnished in collaboration with a physician in all settings in a rural
area, with the exception of hospitals. This provision also allowed for
coverage of services and supplies furnished as an incident to a nurse
practitioner's services if the services would have been covered if
furnished as an incident to a physician's professional services.
The term, ``rural area'' as defined at section 1886(d)(2)(D) of the
Act means any area outside a Metropolitan Statistical Area or New
England County Metropolitan Area, as defined by the Executive Office of
Management and Budget, or outside any similar area the Secretary has
recognized by regulation as an urban area.
Sections 4155(b) and (c) of OBRA 1990 imposes a civil monetary
penalty not to exceed $2,000 on any person who knowingly and willfully
presents a bill or request for payment to a Medicare beneficiary
(except for coinsurance and deductible amounts) for nurse practitioner
services furnished in a rural area, or for services and supplies
furnished as an incident to those services, and for nurse practitioner
services furnished in a SNF or nursing facility.
Section 147(e)(4) of the Social Security Act Amendments of 1994
(SSAA'94) (Pub. L. 103-432) unbundled payment for nurse practitioner
services in SNFs and nursing facilities. It also added nurse
practitioner services to the list of services that are excluded from
the definition of inpatient hospital services. Accordingly, nurse
practitioners or their employer or contractor were authorized to bill
directly for services furnished to patients in SNFs or nursing
facilities and hospitals located in rural areas.
2. Coverage and Payment for Nurse Practitioner Services Subsequent to
BBA 1997
Effective for services furnished on or after January 1, 1998,
section 4511 of BBA 1997 authorizes nurse practitioners to bill the
program directly for services furnished in any setting, regardless of
whether the settings are located in rural or urban areas, but only if
the facility or other providers of services do not charge or are not
paid any amounts with respect to the furnishing of nurse practitioner
services. Accordingly, a new Sec. 410.75 of this proposed rule
specifies the qualifications for nurse practitioners, lists the
requirements for the professional services of a nurse practitioner and
the requirements for services furnished incident to the professional
services of a nurse practitioner. This new section also proposes a
definition for the collaboration process that is applicable to the
provision of nurse practitioner services.
A new Sec. 405.520(a), (b), and (c) of this proposed rule provides
the general rule, requirements, and penalties for nurse practitioners.
A new paragraph (15) is added to Sec. 410.150(b) to authorize payment
for nurse practitioner services when furnished in collaboration with a
physician in all settings located in both rural and urban areas. A new
paragraph (c) is added to Sec. 414.56 of this rule to set forth the
payment amount for nurse practitioner services.
3. Coverage and Payment for Clinical Nurse Specialist Services Before
BBA 1997
In addition to authorizing Medicare coverage of nurse practitioner
services furnished in rural areas, section 4155 of OBRA 1990 also
authorized the coverage of services furnished by clinical nurse
specialists in rural areas. The coverage provisions for clinical nurse
specialist services furnished in a rural area parallel those
established for nurse practitioner services furnished in rural areas.
That is, clinical nurse specialist services must be furnished in
collaboration with a physician and be the type of physician services
that would otherwise be covered if furnished by a physician.
Additionally, the services must be services that the clinical nurse
specialist is authorized by State law to furnish in the State in which
they are practicing. Furthermore, services furnished as an incident to
the professional services of a clinical nurse specialist are covered if
they are the type of services that would be covered if furnished
incident to a physician's
[[Page 30863]]
professional services and all the incident to requirements are met.
A clinical nurse specialist is defined as an individual who is
legally authorized to perform such services in accordance with State
law, and who meets training, education, and experience requirements as
the Secretary may prescribe in regulations.
Section 147(e)(4) of the SSAA'94 also unbundled payment for
clinical nurse specialist services furnished in SNFs, nursing
facilities, and hospitals. The services of clinical nurse specialists
are now paid under a separate benefit.
Payment for clinical nurse specialist services is made to the
clinical nurse specialist or to his or her employer. As is the case
with nurse practitioners, the services of clinical nurse specialists
furnished to patients in rural health clinics (RHCs), federally
qualified health centers (FQHCs), and health maintenance organizations
(HMOs) are not paid under the respective nurse practitioner or clinical
nurse specialist benefits. Instead, the services that nonphysician
practitioners furnish in RHCs, FQHCs, and HMOs education, and
experience requirements as the Secretary may prescribe in regulations.
Section 147 (e)(4) of the SSAA'94 also unbundled payment for
clinical nurse specialist services furnished in SNFs, nursing
facilities, and hospitals. The services of clinical nurse specialists
are now paid under a separate benefit.
Payment for clinical nurse specialist services is made to the
clinical nurse specialist or to his or her employer. As is the case
with nurse practitioners, the services of clinical nurse specialists
furnished to patients in rural health clinics (RHCs), federally
qualified health centers paid under the respective nurse practitioner
or clinical nurse specialist benefits. Instead, the services that
nonphysician practitioners furnish in RHCs, FQHCs, and HMOs are a part
of the facilities' services and cannot be billed or paid separately.
The payment provisions for clinical nurse specialist services
furnished in a rural area parallel those established for nurse
practitioner services furnished in rural areas. Accordingly, payment
for services is made on an assignment-related basis, the civil monetary
penalty provision for violation of the assignment agreement applies,
and the current Medicare-approved amount for covered clinical nurse
specialist services furnished in rural areas (other than in hospitals)
is limited to the lesser of the actual charge or 85 percent of the
physician fee schedule amount for nonspecialist physician services. For
covered services furnished in hospitals located in rural areas, the
Medicare-approved amount is limited to the lesser of the actual charge
or 75 percent of the physician fee schedule amount for nonspecialist
physician services.
4. Coverage and Payment for Clinical Nurse Specialist Services
Subsequent to BBA 1997
Effective for services furnished on or after January 1, 1998,
Section 4511 of BBA 1997 authorizes clinical nurse specialists to bill
the program directly for services furnished in any setting, regardless
of whether the settings are located in rural or urban areas, but only
if the facility or other providers of services does not charge or is
not paid any amounts with respect to the furnishing of nurse
practitioner services. A new Sec. 410.76(e) of this proposed rule sets
forth this provision.
The new Sec. 410.76(b) sets forth new qualifications for clinical
nurse specialists. Section 410.76(c) describes the conditions of
coverage for clinical nurse specialists services, defines the
collaboration process, and paragraph (d) lists the requirements for
services furnished incident to the professional services of a clinical
nurse specialist.
A new Sec. 405.520(a), (b), and (c) of this proposed rule provides
the general rule, requirements, and civil monetary penalties for
clinical nurse specialists. A new paragraph (15) is added to section
410.150(b) to authorize payment for clinical nurse specialist services
when furnished in collaboration with a physician in all settings
located in both rural and urban areas. A new paragraph (c) is added to
section 414.56 of this rule to set forth the payment amounts for
clinical nurse specialist services.
5. Coverage and Payment for Certified Nurse-Midwife Services
Certified nurse-midwife services were only covered under the
Medicare program when furnished incident to the professional services
of a physician or under the supervision of a physician in RHCs prior to
these individuals gaining statutory authorization to perform services
as independent nonphysician practitioners.
Certified nurse-midwives were defined initially section 1861(gg)(2)
of the Act and 42 CFR 405.2401 (b) as a registered professional nurse
who:
<bullet> Is currently licensed to practice in the State as a
registered professional nurse;
<bullet> Is legally authorized under State law or regulations to
practice as a certified nurse-midwife;
<bullet> Has completed a program of study and clinical experience
for certified nurse-midwives, as specified by the State, or, if the
State does not specify a program--
+ Is currently certified as a nurse-midwife by the American College
of Nurse-Midwives;
+ Has satisfactorily completed a formal education program (of at
least 1 academic year) that, upon completion, qualifies the nurse to
take the certification examination offered by the American College of
Nurse-Midwives; or
+ Has successfully completed a formal educational program that
prepares registered nurses to furnish gynecological and obstetrical
care to women during pregnancy, delivery, and the postpartum period,
and care to newborns, and practiced as a nurse-midwife for a total of
12 months during any 18-month period from August 8, 1976, to July 16,
1982.
Certified nurse-midwife services are defined at section 1861(gg)(1)
of the Act as services furnished by a certified nurse-midwife, and
services and supplies furnished as an incident to those services, that
the certified nurse-midwife is legally authorized to furnished under
State law and that would be covered by Medicare if furnished by a
physician or as an incident to a physician's service.
Effective for services furnished on or after July 1, 1988, section
4073 of OBRA 1987 (Pub. L. 100-203) expanded Part B coverage of the
services of certified nurse-midwives to include services furnished
independently of the supervision of a physician. Subsequently, section
411(h)(4) of the Medicare Catastrophic Coverage Act (MCCA) of 1988
(Pub. L. 100-360) made several technical amendments to section 4073 of
OBRA 1987 to categorize and cover certified nurse-midwife services as
medical and other health services, specify that payment for the
services of a certified nurse-midwife is 80 percent of the lesser of
the actual charge or the amount determined by a fee schedule
established by the Secretary, and limit the fee schedule to 65 percent
of the prevailing charge that would be allowed for the same services
furnished by a physician. Additionally, section 4073 of OBRA 1987
requires that payment for certified nurse-midwife services be paid on
an assignment-related basis and that violators of the assignment
requirements be subject to civil monetary penalties.
Section 6102(f)(7) of OBRA 1989 (Pub. L. 101-239) provided that for
services furnished on or after January 1, 1992, payment is determined
based on the lesser or the actual charge or 65 percent of the Medicare
physician fee schedule.
In 1990, in section 4157 of OBRA 1990 (Pub. L. 101-508) the
Congress
[[Page 30864]]
recognized certified nurse-midwife services as separate and distinct
from hospital services. Accordingly, certified nurse-midwife services
are unbundled from hospital services and are paid separately under the
certified nurse-midwife benefit.
Ultimately, section 13554 of OBRA 1993 (Pub. L. 103-66) amended
section 1861(gg)(2) of the Act to revise the definition of certified
nurse-midwife. The revision eliminated the limitation on coverage to
include services furnished by certified nurse-midwives outside the
maternity cycle. This change was made effective for services furnished
on or after January 1, 1994.
A new Sec. 410.77 of this proposed rule lists the qualifications
for certified nurse-midwives and provides for the conditions for
coverage of certified nurse-midwife services. Paragraph (d) of
Sec. 410.77 lists the coverage requirements for the professional
services of certified nurse-midwives, while paragraph (c) lists the
requirements for services furnished incident to the professional
services of a certified nurse-midwife.
6. Coverage and Payment for Physician Assistant Services Before BBA
1997
For physician assistant services furnished on or after January 1,
1987, section 9338(a) of the Omnibus Budget Reconciliation Act (OBRA)
of 1986 (Pub. L. 99-509) authorized physician assistants to bill the
Medicare program for the type of services that would be considered as
physicians' services, provided that the physician assistant is legally
authorized by the State to furnish such services. Services furnished
incident to the physician assistant's professional services are also
covered if these same services would have been covered when furnished
incident to the professional services of a physician. Under this OBRA
provision, physician assistants furnished their services under the
general supervision of a physician in a hospital, SNF, nursing
facility, or as an assistant at surgery in both rural and urban areas.
In order to have furnished services under the physician assistant
benefit, individuals must have met the qualifications as follows:
1. Be certified currently by the National Commission on
Certification of Physician Assistants to assist primary care
physicians;
2. Have completed satisfactorily a program for preparing physician
assistants that--
<bullet> Was at least 1 academic year in length;
<bullet> Consisted of supervised clinical practice and at least 4
months (in the aggregate) of classroom instruction that prepared
students to deliver health care; and
<bullet> Is accredited by the AMA's Committee on Allied Health
Education and Accreditation; or
3. Have completed satisfactorily a formal educational program for
preparing physician assistants (that does not meet the requirements
listed above) and assisted primary care physicians for a total of 12
months during the 18-month period immediately preceding January 1,
1987. Additionally, effective January 1, 1989, section 4076 of OBRA
1987 (Pub. L. 100-203) authorized physician assistants to furnish their
services under the supervision of a physician in all settings located
in rural areas that were designated under section 332(a)(1)(A) of the
Public Health Service Act as health professional shortage areas
(HPSAs).
Payment for physician assistant services prior to January 1, 1998
was made only on an assignment-related basis to the actual employer of
the physician assistant at 85 percent of the physician fee schedule for
professional services. Payment for the services of a physician
assistant performing as an assistant at surgery was made at 65 percent
of the physician fee schedule. The employer of a physician assistant
might have been a physician, medical group, professional corporation,
hospital, SNF, or nursing facility.
7. Coverage and Payment for Physician Assistant Services Subsequent to
BBA 1997
Effective for services furnished on or after January 1, 1998, the
majority of the conditions for coverage of physician assistant services
as indicated by new Secs. 410.74(a) and (b) remain unchanged with the
exception of the condition for coverage of physician assistant services
furnished in certain areas and settings. Section 4512 of BBA 1997
removes the restrictions on the site of services in which physician
assistants may furnish their professional services, regardless of
whether the settings are located in rural or urban areas. Physician
assistants are authorized to furnish their professional services as
independent nonphysician practitioners to practically all providers of
services and suppliers of services only if the facility or other
provider of services does not charge or is not paid any amounts with
respect to the furnishing of physician assistant professional services.
Accordingly, separate payment may be made for physician assistant
services in all settings with the exception of rural health clinics
(RHCs) and Federally qualified health centers (FQHCs) because Medicare
payment for their services is included in the all-inclusive payment
rate that the program makes to these facilities.
Under new Sec. 410.74(c), we are proposing to amend the
qualifications for physician assistants to recognize certification of
physician assistants by the National Board of Certification of
Orthopedic Physician Assistants. These qualifications will also
recognize academic programs for physician assistants that are
accredited by either the Commission on Accreditation of Allied Health
Education Programs or the American Society of Orthopedic Physician
Assistants.
Additionally, effective January 1, 1998, physician assistants have
the option of furnishing services under a different employment
arrangement with a physician. They can furnish services as an employee
of a physician under a W-2 form employment arrangement or they can
furnish services as an employee of a physician under a 1099 form,
independent contractor arrangement. Under either arrangement, the
employer of the physician assistant must bill the program for physician
assistant services as required under Sec. 410.150(b)(14). However, when
an individual furnishes services ``incident'' to the professional
services of a physician assistant, these ancillary services must meet
the requirements under Sec. 410.74(a)(2)(vi)(B).
The Medicare payment amount for physician assistant professional
services as of January 1, 1998, as stated under new paragraph (d) of
Sec. 414.52, remains at 80 percent of the lesser of either the actual
charge or 85 percent of the physician fee schedule amount for
professional services. However, payment for physician assistant at
surgery services, as also described at new paragraph (d) of
Sec. 414.52, increased to allow Medicare payment at 80 percent of the
lesser of either the actual charge or 85 percent of the physician fee
schedule amount paid to a physician assistant serving as an assistant
at surgery. Also, new Sec. 405.520 provides the general rule,
requirements, and civil monetary penalties for physician assistants who
furnish services under the Medicare program.
IV. Collection of Information Requirements
Under the Paperwork Reduction Act of 1995 (PRA), agencies are
required to provide a 60-day notice in the Federal Register and solicit
public comment before a collection of information requirement is
submitted to the Office of Management and Budget (OMB) for review and
approval. In order to fairly evaluate whether an information
[[Page 30865]]
collection should be approved by OMB, section 3506(c)(2)(A) of the PRA
requires that we solicit comment on the following issues:
<bullet> Whether the information collection is necessary and useful
to carry out the proper functions of the agency.
<bullet> The accuracy of the agency's estimate of the information
collection burden.
<bullet> The quality, utility, and clarity of the information to be
collected.
<bullet> Recommendations to minimize the information collection
burden on the affected public, including automated collection
techniques.
Therefore, we are soliciting public comment on each of these issues
for the information collection requirements (ICRs) discussed below.
<bullet> New ICRs and Related Burden.
Sec. 405.410 (Conditions for opting-out of Medicare.)
Section 405.410(a) states that each private contract between a
physician or a practitioner and a Medicare beneficiary must meet the
specifications of Sec. 405.415.
The burden associated with these requirements is the time to draft,
and then read, sign, photocopy and retain the private contract. It is
estimated that it will take 300 physicians and/or practitioners 2 hours
each to create a contract for a total of 600 hours. It is estimated
that it will take 10 minutes for each to read, sign, photocopy and
retain the private contract for 25,000 beneficiaries for a total of
4,167 hours. The burden for these ICRs total 4,767 hours.
Section 405.410(b) states that the physician or practitioner must
submit to each Medicare carrier with which he or she files claims an
affidavit that meets the specifications of Sec. 405.420.
The burden associated with these requirements is the burden to
draft, sign and submit the affidavit to the Medicare carrier. It is
estimated that it will take 300 physicians and/or practitioners
approximately 2 hours each for a total of 600 burden hours.
Sec. 405.445 (Renewal and early termination of opt-out.)
Section 405.445(b)(2) states that a physician or practitioner must
notify all Medicare carriers with which he or she filed an affidavit of
the termination of the opt-out no later than 90 days after the
effective date of the opt-out period.
The burden associated with this requirement is the time for the
physician or practitioner to notify all Medicare carriers of the
affidavit. It is estimated that it will take 30 physicians and/or
practitioners 10 minutes each for a total of 5 hours.
Section 405.445(b)(4) states that a physician or practitioner must
notify all beneficiaries with whom the physician or practitioner
entered into private contracts of the physician's decision to terminate
opt-out and of the beneficiaries' right to have claims filed on their
behalf with Medicare for the services furnished during the period
between the effective date of the opt-out and the effective date of the
termination of the opt-out period.
The burden associated with this requirement is the time for the
physician and/or practitioner to notify all beneficiaries of his or her
decision to terminate opt-out and of the beneficiaries' right to have
claims filed on their behalf with Medicare. It is estimated that it
will take 30 physicians and/or practitioners each 2 hours to notify
their beneficiaries via bulk mailings for a total of 60 hours.
Sec. 405.455 (Medicare+Choice.)
Section 405.455(a) states that an organization that has a contract
with HCFA to provide one or more Medicare+Choice (M+C) plans to
beneficiaries must acquire and maintain information from Medicare
carriers on physicians and practitioners who have opted-out of
Medicare.
The burden associated with these requirements is the time
associated with acquiring and maintaining information provided by
Medicare carriers on physicians and practitioners who have opted-out of
Medicare. It is estimated that 500 organizations will spend 1 hour
annually to acquire and maintain this information for a total of 500
hours. The total burden for these ICRs is 500 hours.
Estimated Annual Burden
----------------------------------------------------------------------------------------------------------------
Annual
CFR section Responses Average burden per response burden
hours
----------------------------------------------------------------------------------------------------------------
405.410(a)
--Draft document.................... 300 2 hours..................................... 600
--Read, sign, photocopy, retain 25,000 10 minutes.................................. 4,167
document.
------------
Sub-total....................... ........... ............................................ 4,767
------------
405.410(b).............................. 300 2 hours..................................... 600
405.445(b)(2)........................... 30 10 minutes.................................. 5
405.445(b)(4)........................... 30 2 hours..................................... 60
405.455(a).............................. 500 1 hour...................................... 500
------------
Total........................... ........... ............................................ 5,932
----------------------------------------------------------------------------------------------------------------
<bullet> New ICRs Without Burden.
The ICR below is subject to the Act. However, we believe the burden
associated with this ICR is exempt since the burden is imposed by
Sec. 405.410 and meets the specifications in Sec. 405.420.
Sec. 405.445 (Renewal and early termination of opt-out.)
Section 405.445(a) states that a physician or practitioner may
renew opt-out by filing an affidavit with each carrier to which an
affidavit was submitted for the first opt-out period (as specified in
Sec. 405.420), and to each carrier to which a claim was submitted under
Sec. 405.440 during the previous opt-out period, provided the
affidavits are filed within 30 days after the current opt-out period
expires.
The ICRs below are subject to the Act. However, we believe the
burden associated with these ICRs are exempt, as defined by 5 CFR
1320.3(b)(2), because the time, effort, and financial resources
necessary to comply with these requirements would be incurred by
persons in the normal course of their activities. Physicians and
practitioners routinely develop and update a plan of treatment so the
patient understands how often and when he or she will require care. In
addition, physicians and practitioners routinely maintain
[[Page 30866]]
documentation in the patient's medical record.
Sec. 410.61 (Plan of treatment requirements for outpatient physical
therapy and speech language pathology services.)
Section 410.61(e) states that the physician review the plan as
often as the individual's condition requires, but at least within the
first 62 days and at least 31 days after each previous review.
Sec. 415.110 (Conditions for payment: Medically directed
anesthesiology services.)
Section 415.110(b) states that the physician inclusively documents
in the patient's medical record that the conditions set forth in
paragraph (a)(1) of this section have been satisfied, specifically
documenting personal participation in the most demanding aspects of the
anesthesia plan.
The ICRs below are subject to the Act. However, we believe the
burden associated with these ICRs are exempt, as defined by 5 CFR
1320.3(b)(2), because the time, effort, and financial resources
necessary to comply with these requirements would be incurred by
persons in the normal course of their activities. We believe the record
keeping requirements described below are a reasonable and customary
part of the plan of treatment described in section 410.61.
Sec. 424.24 (Requirements for medical and other health services
furnished by providers under Medicare Part B.)
In summary Sec. 424.24(c)(1)(iii) and (3) requires that the
services that were furnished under a plan of treatment that meets the
requirements in Sec. 410.61. If the plan of treatment is established by
a physical therapist or speech-language pathologist, the certification
must be signed by a physician who has knowledge of the case.
Section 424.24(c)(4) states that the first recertification is
required by no later than the 62nd day and subsequent recertifications
are required at least every 31 days. The recertification statement must
indicate the continuing need for physical therapy or speech-language
pathology services and an estimate of how much longer the services will
be needed. Recertifications must be signed by the physician who reviews
the plan of treatment.
<bullet> Currently Approved ICRs.
While the ICRs below are subject to the Act; the burden associated
with this requirement is captured in the HCFA-1500, OMB Number 0938-
0008, Medicare Common Claim Form, which expires on August 31, 1998.
Sec. 405.430 (Failure to perfect opt-out.)
Section 405.430(b)(3) states that the physician or practitioner
must submit claims to Medicare for all Medicare-covered items and
services furnished to Medicare beneficiaries.
Sec. 405.435 (Failure to maintain opt-out.)
Section 405.435(b)(3) states that the physician or practitioner
must submit claims to Medicare for all Medicare-covered items and
services furnished to Medicare beneficiaries.
Sec. 405.440 (Emergency and urgent care services.)
Section 405.440(b)(1) states that when a physician or practitioner
furnishes emergency or urgent care services to a Medicare beneficiary
with whom the physician or practitioner has not previously entered into
a private contract, the physician or practitioner must submit a claim
to Medicare in accordance with both 42 CFR Part 424 and Medicare
instruction (including but not limited to complying with proper coding
of emergency or urgent care services furnished by physicians and
practitioners who have opted-out of Medicare).
We have submitted a copy of this proposed rule to OMB for its
review of the ICRs described above. These requirements are not
effective until they have been approved by OMB.
If you comment on any of these information collection and record
keeping requirements, please mail copies directly to the following:
Health Care Financing Administration, office of Information Services,
Information Technology Investment Management Group, Division of HCFA
Enterprise Standards, Room C2-26-17, 7500 Security Boulevard,
Baltimore, MD 21244-1850, Attn.: Louis Blank, HCFA-1006,
Office of Information and Regulatory Affairs, Office of Management and
Budget, Room 10235, New Executive Office Building, Washington, D.C.
20503, Attn.: Allison Herron Eydt, HCFA Desk Officer
V. Response to Comments
Because of the large number of items of correspondence we normally
receive on Federal Register documents published for comment, we are not
able to acknowledge or respond to them individually. We will consider
all comments we receive by the date and time specified in the DATES
section of this preamble, and, if we proceed with a subsequent
document, we will respond to the comments in the preamble to that
document.
VI. Regulatory Impact Analysis
We have examined the impacts of this proposed rule as required by
Executive Order (EO) 12866, the Unfunded Mandates Act of 1995, and the
Regulatory Flexibility Act (RFA) (Public Law 96-354). Executive Order
12866 directs agencies to assess all costs and benefits of available
regulatory alternatives and, when regulation is necessary, to select
regulatory approaches that maximize net benefits (including potential
economic, environmental, public health and safety effects, distributive
impacts, and equity). A regulatory impact analysis (RIA) must be
prepared for major rules with economically significant effects ($100
million or more annually).
This proposed rule is expected to have varying effects on the
distribution of Medicare physician payments and services. With few
exceptions, we expect that the impact would be limited.
The Unfunded Mandates Reform Act of 1995 also requires (in section
202) that agencies prepare an assessment of anticipated costs and
benefits before proposing any rule that may result in an annual
expenditure by State, local, or tribal governments, in the aggregate,
or by the private sector, of $100 million. This proposed rule will have
no consequential effect on State, local, or tribal governments. We
believe the private sector cost of this rule falls below these
thresholds as well.
A. Regulatory Flexibility Act
Consistent with the provisions of the Regulatory Flexibility Act,
we analyze options for regulatory relief for small businesses and other
small entities. We prepare a Regulatory Flexibility Analysis (RFA)
unless we certify that a rule would not have a significant economic
impact on a substantial number of small entities. The RFA is to include
a justification of why action is being taken, the kinds and number of
small entities the proposed rule would affect, and an explanation of
any considered meaningful options that achieve the objectives and would
lessen any significant adverse economic impact on the small entities.
For purposes of the RFA, all physicians are considered to be small
entities. There are about 700,000 physicians and other practitioners
who receive Medicare payment under the physician fee schedule. Thus, we
have prepared the following analysis, which, together with the rest of
this preamble, meets all three assessment requirements. It explains the
rationale for and purposes of the rule, details the costs and benefits
of the rule, analyzes
[[Continued on page 30867]]