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The Medicare fee schedule marks the Centers for Medicare & Medicaid Services' acceptance of an increase in the relative value units (RVUs) for nursing facility day-management services, according to an analysis by AMDA's government affairs department.

The RVU for code 99315 climbs from 1.13 to 1.28, and that for code 99316 goes from 1.50 to 1.90, cushioning the blow of the 27.4% cut due for most Medicare fees Jan. 1 if Congress doesn't intervene. The two RVU changes could add $4.3 million to the incomes of long-term care physicians in 2012, against what fees would have been under the old RVUs, the government affairs department calculated (see table above).

"The increased values are very appropriate and place the discharge codes in line with the reimbursement for the rest of the family of nursing home codes," said Charles Crecelius, MD, PhD, CMD, AMDAs representative to the AMA's Relative Value Scale Update Committee (RUC).

The final rule also included the CMS's decision not to finalize its proposal to have the RUC review many evaluation and management codes. AMDA had opposed the review, which would have included the nursing-facility family of codes.

In a joint letter Aug. 30, AMDA, the American Academy of Home Care Physicians, and the American Geriatrics Society explained, "The current CPT [Current Procedural Terminology] codes were developed more than 20 years ago and describe an episode of care for patients with defined problem(s) that were intended to be resolved within the timeframe of the visit event. They do not describe the longitudinal care provided to patients with multiple chronic conditions who require extensive care coordination, lifestyle education, and caregiver support ...." The CMS acknowledged the comment in the final rule and stated its intent to work with stakeholders on how to value primary care and patient-centered care management.

AMDA's adviser to the RUC, Dennis Stone, MD, CMD, said, "CMS's decision is a huge leap forward in our battle to identify and value managing the complexities of chronic disease and its multiple comorbidities ... A postsurgical visit is not a geriatric chronic disease visit in needed documentation or value. CMS is now giving those who provide transitional coordination, complex medication regimen review, and end-of-life care oversight the ability to do what other specialties have done for years ... separately identify that work and get paid for it."

In another victory for physicians serving nursing facilities, the CMS final rule also retracted the policy that would have required a physician's or a nurse practitioner's signature on requisitions for many diagnostic laboratory tests.

The policy had been scheduled to go into effect last Jan. 1, but the CMS agreed to reconsider. At that time, AMDA pointed out that implementing this requirement would be particularly troublesome in skilled nursing facilities.

The final rule states that CMS officials "understand there are concerns that certain populations of patients, such as nursing home patients and patients confined to their homes, may have laboratory tests ordered urgently by a distant physician or [nurse practitioner] to obtain information that is imminently needed in order to assess a need for immediate referral to a hospital, emergency department or other facility."