Following a similar initiative on the House side, leaders of the Senate Finance Committee are inviting provider input on Medicare physician payment system reform. Specifically, Chairman Max Baucus (D-MT) and Ranking Member Orrin Hatch (R-UT) are requesting information on: (1) what specific reforms should be made to the physician fee schedule to ensure that physician services are valued appropriately; (2) what specific policies should be implemented that could co-exist with the current physician payment system and would identify and reduce unnecessary utilization to improve health and reduce Medicare spending growth; and (3) within the current fee-for-service system, how can Medicare most effectively incentivize physician practices to undertake the structural, behavioral, and other changes needed to participate in alternative payment models? Additional information, including a full copy of letter from Senators Baucus and Hatch to the health care provider community, is available here. Responses are due by May 31, 2013. The panel also has scheduled a May 14 hearing on "Advancing Reform: Medicare Physicians Payments."
On May 8, 2013, the House Energy and Commerce Subcommittee on Health approved by voice vote H.R. 1407, legislation to reauthorize and combine the Animal Drug User Fee Act and the Animal Generic Drug User Fee Act. TheEnergy and Commerce Committee also recently held hearings on: the Administration’s HHS budget proposal; the Center for Consumer Information and Insurance Oversight and implementation of the ACA; the lack of transparency and consumer driven market forces in U.S. health care system; and the impact of HIPAA on patient care and public safety. The House Ways and Means Health Subcommittee held a hearing on Medicare physician payment reform, and the Senate Finance Committee has scheduled a May 14 hearing on this topic. Other Senate panels also recently held hearings on health policy issues, including: a HELP Committee hearing on "Successful Primary Care Programs: Creating the Workforce We Need"’ a Homeland Security Committee hearing on “Oversight and Business Practices of Durable Medical Equipment Companies”; and a Special Committee on Aging hearing on "The National Plan to Address Alzheimer's Disease: Are We On Track to 2025?"
The chairmen of the House Energy and Commerce Committee and Ways and Means Committee have provided additional details regarding their proposal to repeal the current Medicare physician fee schedule sustainable growth rate (SGR) methodology and replace it with an alternative physician payment system. The update builds on comments received from the public on the panels’ February 7, 2013 outline. Among other things, the expanded proposal discusses processes to determine quality and efficiency measures that focus on evidence while being flexible and specialty-specific; recognizes the role that specialty-specific registries play in quality improvement; and addresses timely performance feedback for providers. Comments will be accepted until April 15 at email@example.com.
Today, the Obama Administration released its proposed federal budget for fiscal year 2014. As widely reported, the budget incorporates an offer the President made to Congress in December 2012 to achieve nearly $1.8 trillion in additional deficit reduction over the next 10 years, including $401 billion in health savings (the Administration observes that this level of cuts would “provide more than enough deficit reduction to replace the damaging cuts required by the Joint Committee sequestration”).
Virtually all provider types – and drug manufacturers – would be impacted by the budget provisions, if adopted as proposed. The budget proposal is certainly subject to change during the legislative process, particularly as the House and Senate leadership pursue alternative budget frameworks, and indeed, gridlock could prevent significant action on entitlement reform this year. Nevertheless, the proposals bear careful monitoring because they could eventually be included in any long-elusive “grand bargain” to reform the Medicare program and reduce the federal debt.
Highlights of the Administration’s Medicare and Medicaid proposals include the following:
Medicare Provider Payments
- Reform the Medicare physician fee schedule/sustainable growth rate (SGR) formula to provide stable payments followed by payment linked to participation in an “accountable payment model.”
- Reduce Medicare coverage of bad debts from 65% generally to 25% over three years starting in 2014.
- Reduce Medicare indirect medical education add-on payments by $11 billion over 10 years.
- Reduce payment for post-acute care services in several ways.
- Reduce payment updates for inpatient rehabilitation facilities (IRFs), long-term care hospitals (LTCHs), skilled nursing facilities (SNFs), and home health agencies (HHAs) by 1.1 percentage points, beginning in 2014 through 2023 (the update could not fall below 0%). This provision would save $79 billion over 10 years.
- Adjust the standard for classifying a facility as an IRF (at least 75% of patient cases admitted to an IRF must meet one or more of 13 designated severity conditions), saving about $2.5 billion over 10 years.
- Equalize IRF and SNF payments for three conditions involving hips and knees, pulmonary conditions, as well as other conditions selected by the Secretary, saving $2.0 billion over 10 years.
- Reduce by up to 3% payments to SNFs with high rates of care-sensitive, preventable hospital readmissions, beginning in 2017, saving $2.2 billion over 10 years.
- Implement bundled payments for post-acute care providers (LTCHs, IRFs, SNFs, and HHAs) beginning in 2018. Payments would be bundled for at least half of the total payments for post-acute care providers. Rates based on patient characteristics and other factors would be set to produce a permanent and total cumulative adjustment of -2.85% by 2020. Beneficiary coinsurance would equal levels under current law. This provision would save $8.2 billion over 10 years.
- Align Medicare payments to rural providers with the cost of care, saving $2 billion over 10 years.
- Align Medicare payment for clinical laboratory services with private sector rates and encourage electronic reporting of laboratory results.
Prescription Drug Provisions
- Reduce payment for physician-administered Medicare Part B drugs from 106% of average sales price to 103% of average sales price. Manufacturers would be required to provide a specified rebate in certain instances as determined by the Secretary “to preserve access to care.”
- Provide Medicaid-level drug rebates for brand name and generic drugs provided to beneficiaries who receive Part D low-income subsidies, saving $123 billion over 10 years.
- Close the Medicare Part D donut hole by 2015, rather than 2020, by increasing manufacturer discounts to from 50% to 75% beginning in plan year 2015.
- Lower Medicaid drug costs by clarifying the definition of brand drugs, excluding authorized generic drugs from average manufacturer price calculations for determining manufacturer rebate obligations for brand drugs, making a technical correction to the Affordable Care Act (ACA) alternative rebate for new drug formulations, and calculating Medicaid federal upper limits based only on generic drug prices. These proposals are projected to save $8.8 billion over 10 years.
- Encourage the use of generic drugs by Part D low-income subsidy beneficiaries by modifying copayments, saving approximately $7 billion over 10 years.
- Improve program integrity for Medicaid drug coverage by directing states to track high prescribers and utilizers of Medicaid prescription drugs; requiring manufacturers to make full restitution to states for any covered drug improperly reported by the manufacturer on the Medicaid drug coverage list; allowing more regular audits and surveys of manufacturers to ensure compliance with Medicaid drug rebate agreement requirements; requiring drugs to be electronically listed with the FDA to receive Medicaid coverage; and expanding penalties for reporting false information for the calculation of Medicaid rebates.
- Increase the availability of generic drugs and biologics by authorizing the Federal Trade Commission to stop companies from entering into “pay for delay” agreements and modifying the length of exclusivity on brand name biologics.
Program Integrity/Efficiency Provisions
- Provide $640 million in combined mandatory and discretionary program integrity funding to implement activities that reduce payment error rates, prevent fraud and abuse, target high-risk services and supplies, and enhance civil and criminal enforcement for Medicare, Medicaid, and CHIP.
- Authorize civil monetary penalties or other intermediate sanctions for providers who do not update enrollment records and permit exclusion of individuals affiliated with entities sanctioned for fraudulent or other prohibited actions from federal health care programs.
- Expand authority to investigate and prosecute allegations of abuse or neglect of Medicaid beneficiaries in additional health care settings.
- Exclude radiation therapy, therapy services, and advanced imaging from the in-office ancillary services exception to the prohibition against physician self-referrals (Stark law), except in cases where a practice meets certain accountability standards, as defined by the Secretary.
- Require prior authorization of advance imaging services.
- Require prepayment review or prior authorization for power mobility devices.
- Allow the Secretary to create a system to validate practitioners’ orders for certain high-risk items and services.
Other Medicare Provisions
- Revise beneficiary cost-sharing requirements, including increased income-related premiums under Parts B and D, a new home health copayment, and increased premiums for beneficiaries with Medigap policies with particularly low cost-sharing requirements.
- Increase the minimum Medicare Advantage (MA) coding intensity adjustment (which decreases MA plan payments to reflect differences in coding practices between Medicare fee-for-service and MA) and align employer group waiver plan payments with MA bids, saving $19 billion over 10 years.
- Strengthen the Independent Payment Advisory Board (IPAB) by reducing the target rate of Medicare cost growth from gross domestic product plus one percentage point to plus 0.5 percentage point.
- Expand the availability of Medicare data released to physicians and other providers for performance improvement, fraud prevention, value-added analysis, and other purposes.
- Base Medicaid rates for durable medical equipment on Medicare rates to save $4.5 billion over 10 years.
- Align Medicaid Disproportionate Share Hospital (DSH) payments with expected levels of uncompensated care to save $3.6 billion over 10 years.
- Affirm Medicaid’s position as a payer of last resort when another entity is legally liable to pay claims.
A 131-page Department of Health and Human Services (HHS) “Budget in Brief” summary discusses these provisions in greater detail, and also addresses other HHS agency budget proposals and discusses HHS’s implementation of private health insurance protections and programs under the ACA.
Due to continuing budget gridlock in Washington, sequestration has been triggered – meaning automatic cuts to a wide range of federal programs, including Medicare payments to providers and health plans. While the Centers for Medicare & Medicaid Services has not yet announced detailed plans for implementing the sequester requirements for its programs, this Alert answers some basic questions about sequestration and how it will impact the Medicare program. Among other things, the Alert addresses what Medicare spending is impacted by sequestration, when the Medicare cuts start, and how long sequestration will last.
The Chairmen of the House Ways and Means Committee and House Energy and Commerce Committee are inviting comments on the outline of a proposal to permanently repeal the sustainable growth rate (SGR) formula for updating Medicare physician fee schedule payments and institute other payment reforms. The lawmakers are considering a three-phase proposal. In the first phase, the SGR formula (which Congress has repeatedly overridden to avoid sharp reimbursement cuts) would be repealed, which would eliminate an estimated 25% across-the-board rate cut in 2014 and any future SGR cuts. In its place, the plan would provide an unspecified “period of predictable, statutorily-defined payment rates.” In phase two, the plan would link payment to performance on physician-endorsed measures of quality of care, while in phase three, physicians could earn additional payments based on efficiency of care. The Committees also are considering addressing several other related issues, including gainsharing, medical liability reform, Independent Payment Advisory Board repeal, and private contracting/balance billing. Comments will be accepted on the plan until February 25, 2013 at SGRComments@mail.house.gov.
House Energy and Commerce subcommittees have held hearings on “Influenza: Perspective on Current Season and Update on Preparedness” and on “SGR: Data, Measures and Models; Building a Future Medicare Physician Payment System.” On the Senate side, the Senate Health, Education, Labor, and Pensions Committee voted to approve H.R. 307, the Pandemic and All-Hazards Preparedness Reauthorization Act of 2013 (which was approved by the House last month), and S. 252, “The Prematurity Research Expansion and Education for Mothers who deliver Infants Early (PREEMIE) Act.” In addition, the Finance Committee held a hearing on ACA health insurance exchanges.
On February 14, 2013, the House Energy and Commerce Health Subcommittee is holding a hearing entitled “SGR: Data, Measures and Models; Building a Future Medicare Physician Payment System.”
The GAO has examined how private-sector efforts to adjust physician payments to reflect quality and efficiency could be applied successfully to the Medicare program. As previously reported, CMS developing a physician value-based payment modifier (Value Modifier), which was mandated by the ACA as a way to reward physicians for providing higher quality and more efficient care. The Medicare Value Modifier is being phased in from 2015 to 2017, with 2013 serving as the initial performance period for the 2015 Value Modifier. Under the final 2013 Medicare physician fee schedule rule, the Value Modifier initially will apply to all groups of physician with 100 or more eligible professionals. These groups will be able to choose two payment calculation options: (1) Value Modifier based strictly on participation in the Physician Quality Reporting System, or (2) Value Modifier based on quality tiering, with payments based on quality and costs. Based on a review of successful private-sector practices, the GAO recommends that CMS: consider rewarding physicians for performance improvement in addition to meeting absolute benchmarks; make more timely Medicare payment adjustments to enhance the significance of the incentive to physicians; and develop a strategy to reliably measure the performance of solo or small group practices. HHS concurred with the recommendations.
On January 2, 2013, President Obama signed into law (via autopen) the “fiscal cliff” deal, H.R. 8, the American Taxpayer Relief Act of 2012 (ATRA). In addition to making well-publicized changes to the tax code, the new law includes numerous Medicare payment provisions. Most notably, the law includes a one-year Medicare physician fee schedule (MPFS) fix that is paid for by approximately $30 billion in other health care (mainly Medicare) spending reductions over 10 years. ATRA also delays until March 2013 the automatic, across-the-board “sequestration” cuts in federal spending imposed by the Budget Control Act of 2011, which was expected to reduce Medicare provider payments by more than $11 billion in fiscal year (FY) 2013 and $123 billion over the period of FY 2013 to 2021 (CBO subsequently estimated that the 2013 cut to Medicare payments now will be approximately $9.9 billion due to changes in the sequestration targets under the ATRA). The delay in sequestration, coupled with the government again reaching its debt ceiling, sets up another near-term battle on federal spending, during which Medicare, Medicaid, and other health care programs could be targeted for even more significant cuts.
The health provisions of ATRA are summarized in our Client Alert.
The Centers for Medicare & Medicaid Services (CMS) has sent several final Medicare calendar year 2013 payment rules to the White House Office of Management and Budget (OMB) for final regulatory clearance. Rules under review will establish final 2013 payment and other policies under the Medicare physician fee schedule, hospital outpatient prospective payment system,, home health prospective payment system (PPS), and end-stage renal disease PPS. Copies of the rules are not available at this point, but they are expected to go on display at the Federal Register in the coming days.
MedPAC is meeting on November 1 -2, 2012 to discuss a variety of Medicare policy issues, including: Medicare payment for ambulance services, reducing the hospitalization rate for Medicare beneficiaries receiving home health care, Medicare payment for outpatient therapy services, geographic adjustment of payments for the work of physicians and other health professional, the role of provider prices in determining private-plan Medicare costs relative to fee-for-service Medicare, Medicare Advantage special needs plans, and Medicare payment differences for ambulatory care services across settings.
On August 1, 2012, CMS is holding a national provider call on its proposals for the Physician Value-Based Payment Modifier under the Medicare physician fee schedule (MPFS). The Value Modifier was mandated by the ACA as a way to reward physicians for providing higher quality and more efficient care. In the final 2012 MPFS rule, CMS adopted performance measures to be used for future MPFS Value Modifier payment adjustments. The proposed 2013 MPFS rule sets forth the Value Modifier payment methodology and phase-in plans.
CMS has sent several major calendar year 2013 proposed Medicare payment rules to the White House Office of Management and Budget (OMB) for final regulatory clearance. Rules under consideration include the proposed Medicare outpatient hospital, ambulatory surgical center (ASC), end-stage renal disease, and home health prospective payment system rules for calendar year (CY) 2013, along with notices updating payment policies for inpatient rehabilitation facilities and hospices for fiscal year 2013. We also expect the CY 2013 proposed Medicare physician fee schedule rule to reach the OMB shortly. While the text of the regulations are not available at this point, we expect that they will be put on display at the Federal Register in the near future. We will be providing summaries of the rules in future updates.
Recent hearings on health policy issues include:
- A House Ways and Means Committee hearing on the impact of limitations on the use of tax-advantaged accounts for the purchase of over-the-counter medication.
- A Senate Finance Committee discussion on “Medicare Physician Payments: Understanding the Past so We Can Envision the Future.”
- A Ways and Means Health Subcommittee hearing on the Medicare DMEPOS competitive bidding program. A GAO report released at the hearing found it is too soon to determine the full effects of competitive bidding on beneficiaries and suppliers.
- A House Energy and Commerce Subcommittee on Oversight and Investigations hearing on “Budget and Spending Concerns at HHS.” At the hearing, the GAO issued a report reiterating its recommendations to minimize improper Medicare payments (such as using prepayment controls to identify potentially-improper DME claims and enhanced payment safeguards for physicians who use advanced imaging services) and improve oversight of Medicaid payments.
In addition, the Senate HELP Committeehas scheduled hearings May 15 and 16 on HIV/AIDS drug costs and health care delivery reforms, respectively. In addition, the House Judiciary Subcommittee on Intellectual Property and Competition is holding a hearing May 18 on health care consolidation and competition after the ACA .
On March 15, 2012, MedPAC released its annual report to Congress on Medicare payment policy. Major recommendations for 2013 are highlighted after the jump.
- Congress should increase acute care hospital inpatient and hospital outpatient payment rates by 1% in 2013; gradually recover past inpatient overpayments due to documentation and coding changes; and gradually reduce outpatient hospital payment rates for evaluation and management office visits to the rate of physician office visits for the same service.
- Congress should repeal the sustainable growth rate (SGR) system for physician services and replace it with a 10-year path of statutory fee-schedule updates. The proposal, first announced in October 2011, would freeze rates for primary care services for 10 years, while other services would be subject to annual payment reductions of 5.9% for 3 years, followed by a freeze. MedPAC also endorsed budget-neutral changes to improve data on which MPFS relative value unit (RVU) weights are based and to redistribute payments to underpriced services, and made recommendations regarding the structure of accountable care organization shared savings payments.
- Congress should eliminate the 2013 update for skilled nursing facilities (SNFs), and direct the Secretary to revise the SNF payment system to redistribute payments away from intensive therapy care that is unrelated to patient care needs and toward medically complex care. The Secretary also should begin rebasing payments in 2014, with an initial reduction of 4% and additional reductions thereafter to align with providers’ costs. The Secretary also should reduce payments to SNFs with relatively high risk-adjusted rates of rehospitalization.
- Congress should eliminate the 2013 market basket update for inpatient rehabilitation facilities and long-term care hospitals, and update the outpatient dialysis payment rate by 1%.
- Congress should update payment rates for ambulatory surgical centers (ASCs) by 0.5% for 2013, require ASCs to submit cost data, and direct the Secretary to implement a value-based purchasing program for ASCs by 2016.
- Congress should direct the Secretary to: begin a two-year rebasing of home health rates in 2013; revise the case-mix system to rely on patient characteristics rather than therapy visits; establish a per episode copay for home health episodes not preceded by hospitalization or post-acute care use; and expand certain program integrity efforts.
- Congress should increase hospice rates by 0.5% for FY 2013 and adopt a series of previous MedPAC recommendations addressing payment and program integrity reforms.
- Congress should modify Part D low-income subsidy copayments for beneficiaries with incomes at or below 135% of poverty to encourage the use of generic drugs when available in selected therapeutic classes (with safeguards to prevent substitutions that are not clinically appropriate).
While MedPAC recommendations are not binding, they are often considered by lawmakers in developing Medicare legislation.
On February 22, 2012, President Obama signed into law H.R. 3630, the Middle Class Tax Relief and Job Creation Act, which was approved by Congress on February 17. In addition to extending a payroll tax cut through the end of the year and extending unemployment benefits, the new law includes a number of Medicare and Medicaid provisions, including a provision temporarily averting a steep cut in Medicare physician payments. The following are highlights of the health policy provisions included in H.R. 3630 and accompanying conference report (House Report 112-399).
- Temporarily blocks a 27.4% cut in the Medicare physician fee schedule set to go into effect March 1, 2012 as a result of the statutory Sustainable Growth Rate (SGR) formula, and instead extends current Medicare payment rates through December 31, 2012. The conference report also requires the Secretary of the Department of Health and Human Services (HHS) to report on bundled or episode-based payments to cover physicians' services for one or more prevalent chronic conditions or major procedures, and it requires a Government Accountability Office (GAO) report examining private sector initiatives that tie physician payment rates to quality, efficiency, and care delivery improvement, such as adherence to evidence-based guidelines.
- Extends Medicare Modernization Act (MMA) section 508 hospital geographic reclassifications through March 31, 2012.
- Extends outpatient hold harmless payments through December 31, 2012 (except for sole community hospitals with more than 100 beds), and requires an HHS study on which types of hospitals should continue to receive hold harmless payments.
- Extends the 1.0 floor used in the physician work geographic adjustment through December 31, 2012.
- Extends the Medicare outpatient therapy cap exceptions process through December 31, 2012. The provision also temporarily extends the therapy cap to services received in hospital outpatient departments through December 31, 2012. Effective with services provided on or after October 1, 2012, the Secretary must ensure that therapy claims for which an exemption is requested include appropriate modifiers indicating that such services are medically necessary. The National Provider Identifier (NPI) of the physician who reviews therapy plans also must be included on Medicare claims. In addition, the Secretary is directed to implement a manual medical review process for beneficiaries whose annual spending for therapy services furnished in calendar year 2012 reaches $3,700 for physical therapy and speech-language pathology, or $3,700 in occupational therapy (the GAO subsequently must issue a report regarding this manual review process). The law also directs the Medicare Payment Advisory Commission (MedPAC) to issue recommendations on how to improve the Medicare outpatient therapy benefit to reflect individual acuity, condition, and therapy needs of the patient. Finally, the Secretary is required to implement, beginning on January 1, 2013, a claims-based strategy to collect data on patient function during the course of therapy services in order to better understand patient condition and outcomes in order to assist in reforming the Medicare outpatient therapy payment system.
- Extends authorization for independent laboratories to receive direct payments for the technical component for certain pathology services through June 30, 2012.
- Extends the add-on payment for ground and air ambulance services, including in super rural areas, through December 31, 2012 and requires related MedPAC and GAO reports.
- Bad debt reimbursement for all Medicare providers is reduced gradually to 65%. Specifically, providers now paid at 100% will have a three-year transition of 88% in 2013, 76% in 2014, and 65% in 2015, while providers now paid at 70% will be reduced to 65% in 2013. (This provision saves $6.9 billion over 11 years).
- ReducesMedicare clinical laboratory fee schedule rates by 2 percent in 2013, and the reduced fee schedules will serve as the base for 2014 and subsequent years (saving $2.7 billion over 11 years).
- Extends Medicaid disproportionate share hospital (DSH) payment reductions under the Affordable Care Act (ACA) for an additional year (saving $4.1 billion over 11 years).
- Makes technical corrections to the ACA “disaster recovery federal medical assistance percentage (FMAP) provision ($2.5 billion in savings over 11 years).
- Reduces funding for the ACA Prevention and Public Health Trust Fund by $5 billion over 10 years.
Other Health Provisions
- Extends through December 31, 2012 the Qualifying Individual (QI) program (which allows Medicaid to pay the Medicare Part B premiums for certain low-income Medicare beneficiaries) and the Transitional Medical Assistance (TMA) program (which allows low-income families to keep Medicaid coverage as they transition into employment).
Physician Value-Based Payment Modifier Program: Experience from Private Sector Physician Pay-for-Performance Programs (Feb. 29)
On February 29, 2012, CMS is hosting a National Provider Call to discuss the ACA requirement that CMS apply a value modifier to Medicare physician payments. The value modifier will compare the quality of care furnished to the cost of that care, starting with specific physicians and physician groups in 2015 and expanding to all physicians by 2017. This National Provider Call will include presentations from a panel of three private sector experts with experience in implementing physician-level pay-for-performance programs. The second call in the series, scheduled for March 14, will feature three additional private sector experts. Registration is required.
New Law Provides Short-Term Medicare Physician Fee Schedule Fix and Extends Expiring Medicare Provisions for Two Months
On December 23, 2011, President Obama signed into law H.R. 3765, the Temporary Payroll Tax Cut Continuation Act of 2011. Among other things, the law freezes Medicare physician fee schedule (MPFS) rates at 2011 levels through February 2012, temporarily averting a scheduled 27.4% cut under the statutory Sustainable Growth Rate (SGR) formula. The measure also extends for two months certain Medicare policies set to expire December 31, 2011, including: the floor used in the physician work geographic adjustment; the Medicare outpatient therapy cap exceptions process; payment for the technical component of certain physician pathology services; certain ambulance add-on payments; physician fee schedule mental health add-on payment; the outpatient hold harmless provision; minimum payment for bone mass measurement; the Qualified Individual program that reimburses states for certain Part B premiums; and the Transitional Medical Assistance program. The bill also extends for two months the authority for Medicare Modernization Act section 508 hospital reclassifications, with special rules for October and November 2011. A CMS summary of the law is available here. Note that the final version of the legislation does not include provisions adopted earlier by the House of Representatives to pay for a 2-year SGR fix through a variety of Medicare, Medicaid, and Affordable Care Act (ACA) cuts. When Congress reconvenes, Congressional leaders are expected to tackle legislation to address these Medicare policies at least through 2012, although the outcome of such efforts is speculative at this point. Note that given the uncertainties associated with MPFS rates for 2012, the Centers for Medicare & Medicaid Services (CMS) is extending the 2012 Annual Participation Enrollment Period for health professionals through February 14, 2012 (although the effective date for any participation status change remains January 1, 2012 and will be in force for the entire year).
On January 4, 2012, CMS published corrections to the final 2012 Medicare physician fee schedule rule and the final Medicare hospital outpatient prospective payment system and ambulatory surgical center rule.