Call for Comments:
CMS Proposing major changes in fee schedules

The Centers for Medicare & Medicaid Services (CMS) is proposing significant changes to the fee schedule that are important and dramatic for Osteopathic physicians!  
A few important points of the proposed fee schedule (read the entire 1,472-page proposal here).
CMS proposes to pay the same fee for multiple levels of outpatient visits. Payment for new patient office visits level 2-5 (99202-99205) would be blended into a single $135 payment. Payment for an established patient office visit level 2-5 (99212-99215) would be blended into a $93 payment.

When an E/M service and procedure is reported on the same date, CMS proposes to implement a 50% multiple procedure payment reduction to the lower paid of the two services.

This is an URGENT issue for OMT providers and other physicians who perform procedures as it will cut the payment by 50%.    

Physicians will be paid for telephonic services/assessments, including preventive services, and paid for time to review video or image sent by patient seeking care or diagnosis for ailment.
CMS proposes a minimum documentation standard that requires physicians to only document information to support a level 2 E/M visit (for Medicare Physician Fee Schedule only). Physicians would not have to re-enter information into the medical record but only review and verify certain information entered by ancillary staff or beneficiaries.


The MOA is concerned that this will especially burden the chronically ill, older patients and will actively discourage doctors from caring for older and more medically complex patients.  Furthermore, this reduced documentation will make care transitions and communications between physicians more difficult.   

The CMS is collecting public comments on the proposed fee schedule until Sept. 10, 2018 and we urge our membership to comment on the proposed changes. 

Please take a minute to submit your comments before the September 10th deadline.  We have only a short time to let the CMS know that these changes are not good for physicians or patients.

Link: CMS Call for Public Comments
The information in this communication is accurate as of August 28, 2018 and is subject to change after public comments have been reviewed.


Prescriber Concerns with LARA and MAPS regulations


UPDATE JULY 3, 2018: 
Based on feedback from stakeholder groups, LARA has revised their FAQ on Michigan Opioid Laws as of July 3, 2018. The specific changes, as well as updates on other rule changes and MAPS registrations, can be accessed on the MAPS "Laws and Regulations" webpage.

The MOA has created a page dedicated to providing links to resources regarding the Michigan Automated Prescription System (MAPS)and the regulations for prescribers. This page also includes a link to a comment form designed to allow MOA members an avenue for submitting questions, concerns and examples of issues regarding the new regulations regarding MAPS.

If you have concerns or examples of why the new rules will present obstacles to your practice and providing quality patient care please submit your comments by clicking on the MOA MAPS Comment form below. 

MAPS Information and Resource page 




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Opioid Prescribers' Legislative Alert

On December 27, 2017, the Lieutenant Governor signed into law several new requirements aimed at combating the opioid epidemic. The MOA is part of a coalition that is working with the Department of Health and Human Services (MDHHS) to provide input from healthcare professionals in regards to the laws, regulations and systems used by prescribers. 

For MOA members, a page has been created with an overview, a link to a summary (PDF) and a link to a survey designed to get feedback from the MOA membership.

Opioid Alert page (MOA login page)
Michigan Automated Prescription System (MAPS) - User Support Manual