Urgent Call for Comment Letters
to CMS (Medicare): Significant Anesthesia Conversion
Factor Increase Hangs in Balance
Ronald Szabat, J.D., LL.M.
Executive Vice-President – External Affairs
and General Counsel
ight now, ASA has the best opportunity in more than
a decade to send a strong message to the Centers
for Medicare & Medicaid Services (CMS) in support
of a significant increase in Medicare payments for
anesthesia services. But this increase will not
happen without strong action by all ASA members!
Earlier this year, Medicare’s Relative Value
Update Committee (RUC) submitted a well-developed,
econometrically based recommendation to CMS to boost
the anesthesia conversion factor. This model, developed
by ASA, calculated a 32-percent work undervaluation,
which, if now corrected, would result in an increase
of more than $3 per unit.
ASA has spent years fighting for a correction to
Medicare’s anesthesia conversion factor. And
we owe a great debt of gratitude to our group of
ASA volunteer physician members, together with staff,
who developed a method of proving that this undervaluation
of anesthesia work was sufficiently compelling to
convince the RUC to make this recommendation to
CMS. In its July 2 proposed rule, CMS proposed to
accept the RUC recommendation.
But, dear members, this payment increase is not
certain unless ASA members voice strong support
and act now. In short, it is imperative that we
send a very strong message to CMS with individual
comment letters supporting the positive payment
update. If you do not take this simple action, we
risk squandering a major opportunity to increase
the Medicare anesthesia conversion factor.
Please follow these simple steps to submit a letter
to CMS electronically as soon as possible before
the 60-day comment period closes on August 31:
• Go to www.cms.hhs.gov/eRulemaking.
• Click “Submit
Electronic Comments on CMS Regulations
With an Open Comment Period.”
• Choose Docket ID CMS-1385-P
and follow prompts to submit comments.
• Copy the text from the sample
letter available at www.ASAhq.org.
Paste the letter into the CMS comment
site under “General Comment.”
Feel free to customize with personal information
or data. |
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Then, please tell your colleagues, partners, administrators,
practice managers, residents and medical students
that we need their help, too. This must be a joint
effort with “all hands on deck,” so
please encourage others to take this important action,
just as ASA President Mark J. Lema, M.D., Ph.D.,
has invited the American Academy of Anesthesiologist
Assistants and the American Association of Nurse
Anesthetists to join in this campaign.
Finally, please let ASA know that you have done
your part. We are committed to generating thousands
of comment letters, and we need your help tracking
the number of letters sent to CMS. Specifically
we would like to acknowledge our state component
societies whose members respond in large number
to this important call to action. Once you send
a comment letter to CMS, please email it to mail@ASAwash.org
with your state listed in the subject line.
ASA is grateful that CMS, at long last, has recognized
the gross undervaluation of anesthesia services
and that the agency is taking steps to address this
complicated issue.
When the resource-based relative value system (RBRVS)
was instituted, it created a huge payment disparity
for anesthesia care, mostly due to significant undervaluation
of anesthesia work compared to other physician services.
Today, more than a decade since the RBRVS took effect,
Medicare payment for anesthesia services stands
at just $16.19 per unit. This amount does not cover
the cost of caring for our nation’s seniors,
and it is creating an unsustainable system in which
anesthesiologists are being forced away from areas
with disproportionately high Medicare populations.
But again, to ensure that your patients have access
to expert anesthesiology medical care, it is imperative
that CMS follow through with the proposal in the
Federal Register by fully and immediately
implementing the anesthesia conversion factor increase
as recommended by the RUC.
Kindly help ASA help you by acting today! Your comment
letters to CMS can and will make a real difference!