14TH ANNUAL CAC-PIAC
14th Annual Joint
National Podiatric
CAC-PIAC
Representatives’ Meeting
November 7-8, 2014
Washington, DC
14TH ANNUAL CAC-PIAC
Meeting Materials
 Located on the APMA CAC-PIAC page:
www.apma.org/CACPIAC
 Available to all APMA and state component members
14TH ANNUAL CAC-PIAC
Update on Medicare Physician Fee Schedule for
CY 2015 and Physician Payment
 Important Takeaways: Kathy Bryant, JD, CMS, HHS
• Medicare Physician Fee Schedule final rule, unveiled on October 31, to be published in
the Federal Register on November 13.
• Conversion of 10- and 90-day global surgical services to 0-day global services by CY
2017 and CY 2018, respectively, fraught with challenges.
• For misvalued codes, if reductions do not meet 0.5%, CMS will have to start reduce
across the board to meet the 0.5% threshold (congressional mandate).
• CMS initiatives may not currently offer opportunities for podiatry but could in the
future.
14TH ANNUAL CAC-PIAC
Medicare Policy Issues for DPMs
 Important Takeaways: Henry Desmarais, MD, MPA, Health Policy
Alternatives
• DPMs will see no change on average to total allowed charges.
• Conversion to 0-day global services may not impact podiatrists as negatively as other
specialties.
• Value-based modifier: for CY 2017, 10+ group practice (positive, negative, neutral
impact), solo practitioners and 2+ group practice (positive, neutral impact).
• Must satisfy PQRS requirements to avoid decrease.
• Continuing medical education (CME)-related changes affecting the Open
Payments/Sunshine Act reporting requirements restore a level playing field for CME
programs in podiatry.
• DPMs (and all other physicians) need to start paying far more attention to the Quality
and Resource Use Reports (QRURs) made available by CMS.
14TH ANNUAL CAC-PIAC
Understanding Physician Supplier Enrollment
and Related Issues
 Important Takeaways: Erika D. Williams, MPA, NSC
• Know, review, and comply with the supplier standards.
• If physician–supplier has hours posted, PECOS/CMS-855S must reflect posted hours
(unannounced site inspections may occur at any time).
• To report system/navigation issues with PECOS, contact the External User Services
(EUS) Help Desk at 1-866-484-8049.
• Contact the NSC for general enrollment questions.
• Beneficiaries are serviced must have billing privileges.
• 42 CFR 424.57 requires every supplier to revalidate every 3 years (revalidation
materials sent in a yellow envelope).
• CMS Revalidation List notifies suppliers if revalidation has been mailed.
14TH ANNUAL CAC-PIAC
Physician Regulatory Issues
 Important Takeaways: William Rogers, MD, CMS
• Stressed the ever increasing cost of health care in the US.
• Trend of increasing enrollment in Medicare Advantage plans.
• Congressional focus on audit programs (RACs, ZPICs), which bring
money back.
14TH ANNUAL CAC-PIAC
PQRS and Meaningful Use
 Important Takeaways: Jim Christina, DPM, APMA
• 2014 is last year where participating in PQRS and meaningful use is not
mandatory.
• For PQRS in 2015, no more incentive payments so participation is required to
avoid the 2017 payment reduction (2% of all Medicare Part B FFS payments).
• In the future, becoming increasingly difficult to participate in PQRS without
an EHR.
• New CMS guidance on when to complete a security risk analysis: Must be
conducted/review during each program year for Stage 1 and 2.
• Hardship exception applications to avoid the 2015 Medicare payment
adjustment due November 30.
14TH ANNUAL CAC-PIAC
Emerging Issues in Private Insurance
 Important Takeaways: Kelli Back, Esq.
• Consider the pros and cons of participating in Medicare Advantage
Organizations.
• Stay tuned for updates on federal agency guidance on the ACA
provider non-discrimination provision.
• Be aware of your rights in regards to provider terminations.
• Be aware of your rights and responsibilities when acting as an
authorized representative.
• Template letter located in the APMA Private Insurance Resource
Guide (PIRG), www.apma.org/PIRG.
14TH ANNUAL CAC-PIAC
Leading Sources of Audits and How to
Protect Your Practice
 Important Takeaways: J. Kevin West, Esq.
• To avoid audits, investigations and big overpayments, DPMs should:
• implement and follow a written corporate compliance plan
• Available at www.apma.org/compliancemanual
• have competent, well-trained billing staff or billing service; and
• use all available resources to stay informed.
• E.g., APMA Coding Resource Center, www.apmacodingrc.org
• Examples of most commonly audited codes
• Current audit environment
14TH ANNUAL CAC-PIAC
Additional Highlights
 APMA Federal Legislative Update
 APMA Health Policy and Practice Initiatives
 Coding Update (ICD-10, modifier 59)
 BMAD
 DME Panel
 CAC Breakout Session
 PIAC Breakout Session