Each July, the Centers for Medicare & Medicaid Services (CMS) publishes in the Federal Register its proposals for updating the Medicare physician fee schedule for the upcoming calendar year.1 The rule applies to the approximately 37 million beneficiaries in the fee-for-service program. Following a 60-day public comment period, the CMS finalizes the rule and typically implements it the following January. Although these rules cover a wide range of services, included within the document issued this past July is a little-noticed discussion of Medicare’s intent to make a substantial change in its payment policy. If the rule is finalized as proposed, for the first time physicians would be able to bill Medicare for the non–face-to-face delivery of complex chronic care management services provided by a practice that has the capability to furnish these services.
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