2015 RVUs for Observation

Observation services were also revalued for 2015, resulting in some small adjustments (Tables 3–5).

Subsequent observation services remained relatively stable from 2014 to 2015 (Table 6).

Critical Care Services

Critical Care Services were also revalued as part of the Final Rule and received small changes (Table 7).

Elimination of the Global Surgical Package for Procedures

CMS has proposed to eliminate the 10-day global and 90-day global package for most procedures. In effect, the RVUs would be lowered substantially and follow-up care would not be included with the payment for the initial procedure. CMS proposed to make this transition for procedures with a 10-day global in 2017 and for those with a 90-day global in 2018. ED providers would continue to bill for procedures such as incision and drainage, joint reductions, etc. However, the RVUs would be significantly reduced. However, upon a patient’s return to the ED for additional care, the opportunity might exist to report 9928x for those follow-up visits.

Regulatory Update: Physician Quality Reporting System

The Physician Quality Reporting System (PQRS) continues for 2015. While 2014 PQRS included small bonuses, 2015 simply has a penalty component. Groups not reporting PQRS measures in 2015 will receive a 2 percent penalty assessed against their 2017 Medicare allowables.

Beginning in 2015, the CMS’s Physician Compare website, in addition to continuing to report basic physician-identifying information, will also display a green check mark for those satisfying the Maintenance of Certification (MOC) requirements. For 2015, CMS retired 50 PQRS measures, including four measures frequently utilized by emergency physicians:

• #28: Aspirin for acute myocardial infarction
• #55: 12-lead ECG for syncope
• #56: Pneumonia (CAP): vital signs
• #59: Pneumonia (CAP): empiric antibiotic

2015 Value-Based Modifier (VBM)

The Affordable Care Act requires CMS to apply a VBM to physician payments for all providers by 2017. For 2015, groups with 10 or more providers will be subject to a VBM penalty of -4 percent. The VBM penalty will be applied to 2017 payments based on 2015 reporting. The VBM penalty will be avoided if at least 50 percent of the providers within a group satisfy the minimum PQRS reporting requirements in 2015.
For additional detail regarding 2015 PQRS, visit the ACEP website.

2015 CPT Coding Changes

The CPT book is published annually, and for 2015, there are 143 deletions, 134 revisions, and 264 CPT code additions, totaling 541 changes. The code changes impacting emergency medicine are listed below.