Proposed Medicare Physician Payment Schedule
for 2017: Impact on Interventional Pain
Management Practices
Authors: Manchikanti Laxmaiah 
Published: February 2021

The Centers for Medicare and Medicaid Services (CMS) released the proposed 2017
Medicare physician fee schedule on July 7, 2016, addressing Medicare payments for
physicians providing services either in an office or facility setting, which also includes
payments for office expenses and quality provisions for physicians. This proposed rule
occurs in the context of numerous policy changes, most notably related to the Medicare
Access & CHIP Reauthorization Act of 2015 (MACRA) and its Merit-Based Incentive Payment
System (MIPS). The proposed rule affects interventional pain management specialists in
reimbursement for evaluation and management services, as well as procedures performed
in a facility or in-office setting.
Changes in the proposed fee schedule impacting interventional pain management practices
include adjustments to the meaningful use (MU) program, care management in patientcentered services, identification and review of potentially misvalued services, evaluation
of moderate sedation services, Medicare telehealth services, updated geographic practice
cost index, data collection on resources used in furnishing global services, reporting of
modifier 25 for zero day global services, Medicare Advantage Part C provider and supplier
enrollment, appropriate use criteria (AUC) for advanced imaging services, and Medicare
shared savings programs.
The proposed schedule has provided rates for new epidural codes with or without imaging
(fluoroscopy or computed tomography [CT]) and a fee schedule for a new code covering
endoscopic spinal decompression. Review of payment rates show major discrepancies
in payment schedules with high payments for hospitals, 2,156% higher than in-office
procedures. Some procedures which were converted from in-office settings to ambulatory
surgery centers (ASCs) are being reimbursed at 1,366% higher than ASCs. The Medicare
Payment Advisory Commission (MedPAC) recommendation on avoiding the discrepancies
and site-of-service differentials in in-office settings, hospital outpatient settings, and ASCs
has not been agreed to by CMS. Thus, even though the changes appear to be minor in
physician services and in-office service payment, these changes cumulatively have been
reducing payments for interventional procedures. Further, in-office reimbursement is overall
significantly lower than ASCs and hospital outpatient departments (HOPDs) specifically for
intraarticular injections, peripheral nerve blocks, and peripheral neurolytic injections. The
significant advantage also continues for hospitals in their reimbursement for facility fee for
evaluation and management services.
This health policy review describes various issues related to health care expenses, health care
reform, and finally its effects on physician payments for all services and also for the services
provided in an office setting.
Key words: Physician payment policy, physician fee schedule, Medicare, Merit-Based
Incentive Payment System, interventional pain management, regulatory tsunami, Medicare
Access and CHIP Reauthorization Act of 2015