As expected, CMS released its final 2010 Medicare Physician Fee Schedule at just a little before 5 today. I'll have more later this weekend, but here's the quick and dirty summary for now...
Final Rule Includes Phased In
Cuts for Cardiology
The Centers for Medicare and Medicaid Services (CMS) today released its
2010 Medicare Physician Fee Schedule final rule, which includes policy
proposals that will significantly reduce payments for cardiovascular-related
services. While CMS has attempted to mitigate the impacts of the cuts
by spreading them out over a four-year period, the impact of the cuts
is still enormous both for 2010 and beyond. Cuts of this magnitude—whether
enacted this year or spread over four—cannot be absorbed and we
will continue to fight the implementation of this data until a rigorous
review is conducted.
The ACC understands the very real impacts these cuts will have on your
practices, your staff and your patients. The College is exploring all
options and staff and leaders are working together to help you understand
all of your options. Below is a high-level summary of the policy changes
finalized in the rule. In addition, we’ve also provided links to
the tools and resources available to you now.
More information over the coming weeks will be provided in Cardiology
magazine, ACC News and The ACC Advocate. Please also
plan to join ACC CEO Jack Lewin and President Alfred Bove, M.D., F.A.C.C.,
for an all-member call on Nov. 12 from 4:00 to 5:30 p.m. (EST) to discuss
the 2010 rule. To RSVP for the call, click
Practice Expense: Despite the hundreds of calls and
letters from you, members of Congress and patients, CMS has chosen to
incorporate the results of the American Medical Association’s Physician
Practice Information Survey into its formula for calculating practice
expense relative value units (RVUs). In a slight change from the proposed
rule, the agency has said the cuts will be phased in over a four-year
period versus all at once. With the exception of evaluation and management
services, nearly all services that cardiologists perform will see cuts
ranging from 10 percent to more than 40 percent for individual services
phased in over 4 years. A few key examples for 2010 alone:
- SPECT Myocardial Perfusion Imaging (78452) – 36 percent cut
- Transthoracic echo with spectral and color flow Doppler (93306)--10
- Coronary Stent (92980) - 4 percent cut
- EKG (93000 )-- 5 percent cut
- Level 4 established patient office visit (99214) -- 7 percent increase
As mentioned above, the ACC is exploring several options for stopping
the implementation of these cuts. CMS’ decision to phase-in the
cuts, while not what we would have hoped, is due in large part to your
tremendous efforts over the last few months. Your actions clearly had
an impact and we strongly encourage you to continue to email your congressional
representatives and CMS detailing the ramifications of these cuts as we
move into the next phase of challenging these cuts.
Bundled codes for myocardial perfusion/SPECT imaging
CMS’s continued pressure to bundled together imaging services reported
with multiple codes has now hit myocardial perfusion imaging. In 2010
myocardial perfusion imaging/SPECT studies including wall motion and ejection
fraction will now be reported with a single code. CMS decided to substantially
reduce the payment for myocardial perfusion imaging as part of this rule
by reducing both the physician work value and the practice expense value.
To make matters worse, because there is a new code for the service, CMS
apparently is not applying the four-year transition of the practice expense
cuts and instead is using the fully implemented value. The result is a
36% cut in payment for 2010. This change alone accounts for more than
one-third of the projected payment cut to cardiology. ACC will begin immediately
to pursue strategies to mitigate this cut. Specifics on the new codes
and tips on how to work with health plans to transition to the new codes
will be emailed to you next week and also included in the November issue
of Cardiology magazine.
Consultations: Payments for consultations provided in
office and hospital settings are eliminated under the final rule. The
RVUs assigned to these codes will be redistributed to office and hospital
visits and services now billed as consultations will be billed as hospital
or office visits. This will reduce payments to varying degrees for consultation
Malpractice: CMS has chosen to update the malpractice
RVUs with data from a new survey of specialty-level malpractice premiums.
In addition, CMS has proposed a new method for determining malpractice
RVUs for technical component services. The proposed new malpractice RVUs
would reduce cardiology payments by 1 percent. However, the impact will
vary depending on the mix of services provided.
Equipment utilization: CMS has finalized its proposal
to change the agency’s formula for calculating the per-procedure
cost of diagnostic medical equipment worth more than $1 million. The proposal
would assume that all diagnostic equipment with an acquisition cost greater
than $1 million is used 90 percent of the time an office is open, thus
driving down the practice expense RVUs for services using that equipment.
Within cardiology, cardiac MR and cardiac CT services will be subject
to payments set based on this utilization assumption. CMS did agree not
to apply this cut to equipment for non-hospital cardiac catheterization
SGR: As required by current law, the final rule includes
a 21.5 percent reduction in Medicare Physician Payment as of Jan. 1, 2010.
This cut is in addition to the payment reductions that
result from the proposed policy changes described above. In short, there
could be as high as a 30 percent cut in Medicare payments for cardiology.
However, as in previous years, Congress is expected to pass a one to two
year fix this fall. CMS did finalize its proposal to remove physician-administered
drugs from the accumulated SGR debt, which makes a fix to SGR less expensive.
Taken together with the payment cuts cardiology has already experienced,
CMS’ final rule represents a grave threat to cardiology practices
and to patient access. The consequences, whether intentional or not, are
already being felt. The ACC and its partners in the cardiology community
are prepared to help you and your practice navigate these challenging
times, while also pulling out all the stops to stop the practice expense
cuts and find real solutions to payment. The following resources are available
to you now. Your feedback on the tools and resources you’d like
to see in the coming months is also appreciated. Please email email@example.com
with your thoughts.
- Practice Management
Toolkit: This newly updated site contains information designed to
help you best manage your practice. While continually being updated,
you’ll find information on practice solutions, health IT, coding
and billing, working with health plans, quality and educational tools,
Provider Enrollment Website: This CMS site provides you information
about Medicare enrollment. The ACC will provide information to members
on options in future communications.
- ACC CardioAdvocacy
Network / ACC
Political Action Committee: The ACC’s CardioAdvocacy Network
(CAN) keeps you up to date on ACC’s grassroots efforts and ways
you can get involved. Currently the site contains links to a sample
congressional letter regarding the final rule. The ACC Political Action
Committee (PAC) is another way to ensure the cardiovascular voice is
heard on Capitol Hill. There’s no better time to get involved
with either or both of these key advocacy programs.