As described in the revised Medicare Part D Drug Inflation Rebate Guidance, CMS intends to calculate the average annual total cost based on gross covered drug costs for the Part D rebatable drug at the NDC-9 level
In general, except where a formal transfer of care modifier applies, a practitioner other than the proceduralist or a practitioner in the same group practice as the proceduralist can bill separately for an E/M visit for services they furnish during the global period for a global package, including post-operative E/M visits related to the procedure
The measure should account for patients with cardiac arrest and patients who smoke tobacco to reduce factors outside of clinician control that influence measure performance
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We believe it remains important to reflect on the challenges with our current methodology, and to continue to consider alternatives that improve the stability and accuracy of our overall PE methodology
++ Establish a calculation methodology to account for the impact of improper payments in recalculating expenditures and payment amounts used in Shared Savings Program financial calculations upon reopening a payment determination pursuant to 425.315(a) (section III.G.7.c of this proposed rule)