While the ACC commended the Senate for its ideas in the paper “Transforming the Health Care Delivery System: Proposals to Improve Patient Care and Reduce Health Care Costs,” the college also disagreed with senators on several points in the eight-page letter.Regarding quality outcomes, the college said that performance measurement is critical to quality improvement, and that the physician quality reporting initiative (PQRI) constituted an "important starting point" for Medicare. However, the ACC noted that the initiative is "far from an ideal performance measurement system," and expressed "serious concerns about moving forward with penalties under the current PQRI program.... PQRI has considerable administrative issues that must be addressed to help physicians successfully participate."
For instance, the ACC exemplified how practices were deemed unsuccessful participants for PQRI in 2007, and those practices are still trying to determine the reason. To drive real quality improvement, the letter said, the Centers for Medicaid & Medicare Services (CMS) must fix the administrative issues and functional health IT systems and registries must be in place to facilitate clinical data reporting.
The ACC said it is proactively responding to the growth in cardiovascular imaging through the development of appropriate use criteria, and it strongly supported Congress' enactment of a Medicare demonstration project to test the use of appropriate use criteria and mandatory imaging laboratory accreditation in the Medicare Improvements for Patients and Providers Act (MIPPA) in 2008.
However, the college expressed "significant concerns with the proposal to use radiology benefit managers (RBMs) and prior authorization in the Medicare program. While projected as a modest savings...the cost to Medicare for implementing prior authorization would be very expensive with no associated gains in imaging quality. In addition, the implementation of RBM programs would be an extraordinary administrative cost to ordering physicians, including the primary care physicians."
Yet, the letter said that the college supports the Committee's proposals to create a Diagnostic Imaging Exchange Network (DIEN) and to promote adherence to physician-developed appropriate use criteria. The ACC said it wanted to collaborate on a timeline and incentive structures for these programs that are more workable for physicians.
The college said it supports efforts to bolster primary care, such as incentives to encourage physicians to choose primary care and remain in primary care, but does not support offsetting bonuses to primary care by implementing across-the-board reductions in payments for other critical physician services.
The ACC also said it wants to be part of the solution to the high number of hospital readmissions for cardiovascular disease. This summer, the college is launching the "Hospital to Home" program with the Institute for Healthcare Improvement (IHI) with a goal of reducing preventable readmissions for heart failure and acute MI by 20 percent by the end of 2012.
On the other hand, the college said it is "disappointed" that the Committee's policy options do not include a permanent solution to the flawed sustainable growth rate formula, but "strongly supports moving the current Medicare physician payment system away from a volume-based system and toward a value-driven system."
The ACC also said it supported efforts to set appropriate rules that allow for greater transparency in the relationship between healthcare professionals and industry. Measures aimed at the disclosure of industry gifts to physicians should include a reportable aggregate annual amount of $100 or more with annual adjustments for inflation.
The college also commended the Committee for outlining steps the federal government can take to address workforce shortages. In cardiology, there is a current shortage of 1,700 general cardiologists and more than 40 percent of general cardiologists are over age 55 and nearing retirement. A recent report estimates that the cardiology workforce will need to double to keep up with demand in the next 20 years.
To help meet future cardiology workforce needs, the ACC recommended expanding the number of fellowship positions, creating opportunities for part-time work, training for mid-level cardiovascular professionals, as well as incentives for services in underserved communities.
"The current medical liability system is in serious need of reform and strongly encourages you to address it in health reform legislation," the ACC concluded. The college also urged the testing of approaches to reduce the cost of defensive medicine such as health courts, arbitration and providing protection to physicians who participate in Medicare quality incentive programs and have followed guidelines or practiced according to appropriate use criteria.
The entire letter can be accessed here.