Proposed 2019 Medicare PFS: The 5 Things Labs Need to Know

On July 12, CMS issued the proposed 2019 Medicare physician fee schedule (PFS), with comments scheduled to end on Sept. 10. Takeaways:

1. Physician Payment Rates 

CMS is proposing a 0.25% increase in physician payment rates based on a 0.12% budget-neutrality adjustment. The 2019 PFS conversion factor is $36.05, up from $35.99 in 2018.

2. Diagnostic Imaging Tests

CMS would allow diagnostic imaging tests to be furnished under a physician’s direct supervision instead of personal/in-the-room supervision when performed by a radiologist assistant in accordance with state law scope of practice rules. Radiologist assistants would be required to personally perform the test and not supervise a technologist.

3. Changes to E/M Coding and Payment 

In a bid to reduce administrative burdens and improve payment accuracy for E/M visits, CMS wants to allow practitioners to review and verify certain information in a patient’s medical record that’s been entered by ancillary staff or the patient and not have to re-enter the information themselves. A new multiple-procedure payment adjustment would also apply when E/M visits are provided in conjunction with other procedures.

4. New Telehealth Payment Policies 

CMS proposes paying physicians for the time it takes to review a video or image sent by a patient to assess whether a visit is needed in addition for their time when they check in with beneficiaries via telephone or other telecommunications device.

5. The Lack of Changes to OPPS Site-Neutral Payment Policies

Also of note is that CMS is not proposing to change its site-neutral payment policies under Section 603 of the Bipartisan Budget Act. Much to the consternation of hospital groups, the agency wants to continue allowing nonexcepted provider-based departments to bill for nonexcepted services on the institutional claim and maintain payment for nonexcepted services at 40% of the OPPS amount for calendar year 2019. Section 603 requires, with the exception of dedicated emergency departments, services furnished in off-campus provider-based departments that began billing under OPPS on or after Nov. 2, 2015 no longer be paid under OPPS, but under another applicable Part B payment system.


Some of the other proposed changes in the new CFS potentially affecting labs include:

  • Implementation of a Bipartisan Budget Act of 2018 provision pertaining to writing and signature requirements in certain compensation arrangement for purposes of Stark Law exceptions;
  • Addition of mobile stroke units, renal dialysis facilities and the homes of ESRD beneficiaries as Medicare telehealth originating sites;
  • Payment for new communication technology-based service codes; and
  • Discontinuation of certain functional reporting requirements for outpatient therapy services and creation of payment modifiers for services furnished by therapy assistants, which will be paid at 85% of the applicable Part B payment.
  • Changes to the definition of “applicable laboratory” for clinical laboratory fee schedule purposes

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