We're deep into the pages of the proposed 2012 Medicare Physician Fee Schedule and still haven't seen light at the end of the tunnel, but one thing is clear already: weighing in at 621 pages, this is one slim tome compared to the 2011 proposed fee schedule. The 2011 edition was 1,250 pages, which means this year's version is less than half the length, or 49.6% if you want to be precise. TIP: Read our initial fee schedule findings here, if you haven't already.
The biggest reason for the big difference in size has to be the health reform law, which was signed by Obama in 2010, putting the onus on CMS to start turning legislation into actual rulemaking and writing provisions that could be implemented by you and your peers. The final 2011 fee schedule is more than 1,600 pages, reflecting changes as well as the fact that all final rules are longer than proposed rules by default due to CMS commenting on the remarks it received during the public comment period.
In a private conversation with me, a CMS official agreed with my interpretation that the 2012 proposed rule is primarily composed of incremental changes and updates to existing programs and initiatives, aiming at optimizing and harmonizing rather than introducing loads of significant new changes.
Stay tuned for our full story in the next issue of Part B News, which will appear in full on this site Thursday night, and our ongoing coverage of proposed fee schedule changes in future issues.