In comments in two separate letters to the Centers for Medicare & Medicaid Services (CMS), the American College of Cardiology (ACC) has outlined its concerns and support for recently proposed federal rules that could affect cardiology practices.
ACC listed opposition to several components of Medicare’s Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY2012, including the reporting period for e-prescribing; claims-based performance measures in Physician Feedback Reports; inclusion of per-capita costs as a resource measure in Cost of Care measures; measures using physician comparisons on a single scale rather than by a peer group; and adjustment to the multiple procedure payment reduction.
“CMS should endeavor to pay for a service at a rate that reflects providing the service efficiently rather than attempting to continue to adjust for efficiency based on some kind of combination of services,” the college wrote.
Among concerns and recommendations listed by the ACC were:
- Validation issues within the sampling of work relative value units (RUVs);
- Addition of a proposal and comment period for an annual review process to the Relative Value Update Committee (RUC);
- Support of a public nomination process to identify misvalued services;
- Use of the review of E/M codes “to redress perceived inequities in primary care reimbursement”;
- That core measures may not fully represent cardiac care, with recommendations to include coronary artery disease and heart failure for 2012 and beyond; and
- Future payment adjustments to the Physician Quality Reporting System (PQRS) may penalize physicians.
Of the Physician Feedback Program, ACC wrote, “[W]e are concerned by the enormous difficulty the CMS will have implementing this program. The science of performance measurement is still very young and issues related to attribution and comparison, if not considered properly, will sink any program if not very carefully considered in collaboration with physicians.”
In a separate letter concerning Medicare’s Hospital Outpatient Prospective Payment; Ambulatory Surgical Center Payment; Hospital-Value Based Purchasing Program; Physical Self-Referral; and Provider Agreement Regulations on Patient Notification Requirements, ACC supported the proposed changes to the Lower Extremity Revascularization code and changes that minimized reporting burdens. But it cautioned proposals for the Cardiac Resynchronization Therapy Composite code and the use of volume of surgical procedures as a quality measure may be problematic.
“The decisions of CMS in its rulemaking cycle for 2010 had an extraordinary impact on the provisions of cardiovascular care in this country,” the the college stated in its comments on the Physician Fee Schedule and Other Revisions.
“That rule, which decreased payments for some cardiology services by more than 20 percent, led to an increasing movement of cardiologists into hospital employment and integration. Future proposals could have comparable impact on cardiovascular care—our goal in responding to these proposals is to ensure that patients continue to have access to high value cardiovascular care in the most appropriate environment.”