or
more than 40 years, the ASA Relative Value Guide™
(RVG) has stood the test of time as a reasonable
and consistent billing methodology for anesthesiologists.
The system evolved based on changes in the method
of payment for anesthesia services, from direct
payments for anesthesiologists’ services by
hospitals to fee-for-service payments using a flat-fee
methodology as a percentage of the surgeon’s
fee to the current relative value system using base
and time units. The ASA RVG is currently accepted
by all insurers and by the Centers for Medicare
& Medicaid Services (CMS).
When the Medicare Physician Fee Schedule was implemented
in 1992, payment methodology for anesthesia was
not incorporated into the resource-based relative
value scale (RBRVS); for all other specialties,
it was. At that time, however, the Medicare anesthesia
conversion factor (CF) was reduced by 29 percent
from a national average CF of $19.27 to $13.68.
This low CF has persisted, and in 2007 the national
unadjusted Medicare CF is $16.19. Fortunately, due
to the tremendous work of the ASA Committee on Economics
and the Current Procedural Terminology (CPT®)/Specialty
Society Relative Value Scale Update Committee (RUC)
team, CMS (the agency that administers the Medicare
program) has finally recognized the undervaluation
of our services and has proposed to increase the
anesthesia CF to about $20 per unit. Note that adjusting
the CF of $13.68 in 1992 by the average consumer
price index over the last 15 years would produce
a conversion factor of about $20 per unit. We are
now keeping up with inflation — a marked improvement!
Still, a huge discrepancy between the Medicare CF
and private payer CF remains. The General Accounting
Office (GAO), in a recent study called “Medicare
and Private Payment Differences for Anesthesia Services”
(GAO 07-463 www.gao.gov/new.items/d07463.pdf),
found that the average Medicare CF in 2004 was 33
percent of the CF for private payers; this
does not come as a surprise to anesthesiologists.
For other specialties, however, Medicare payment
is approximately 80 percent of private payers. Something
is seriously wrong here.
To complicate matters further, health care expenditures
continue to increase at an unsustainable rate. The
Medicare and uninsured populations continue to grow,
the State Children’s Health Insurance Program
is expanding, and calls for universal health care
are increasing. Health care availability and affordability
are now major political concerns. At the same time,
many anesthesiologists have entered into service
contracts with hospitals and ambulatory surgery
centers to provide payment for services that are
not covered by health insurance, including call
(availability) coverage and administrative responsibilities.
Without these contracts and this additional payment,
anesthesiologists’ incomes would most certainly
fall. With the pending Medicare meltdown (see: Savings
T. Medicare meltdown. Wall Street Journal.
2007; May 9), how long will these contracts be maintained?
These issues are of critical importance to the future
of the specialty.
What can we do about the payment discrepancies?
Some have suggested that the unique method for payment
of anesthesia services — time-based methodology
— is accounting for the lack of equity in
anesthesia payments. Is time the problem? Under
RBRVS, the surgeon receives a single payment for
an individual procedure, no matter how long it takes,
while the anesthesiologist’s payment is based
on time. Anesthesiologists have always argued that
this time-based system is appropriate, since we
do not control time, the surgeon does. In reality,
it is both the surgeon and the patient who control
time. No matter how fast that surgeon is, a difficult
and complicated patient will require more time under
the care of the anesthesiologist. Despite the desire
to maintain time-based payment for anesthesia services,
anesthesia time does not have a lot of support with
the rest of organized medicine. While there are
some codes (e.g., critical care, evaluation and
management [E/M] and moderate sedation) that include
a time component, time is not a separate component
of the 6,000+ other CPT codes. So the common position
is that since they do not have it, why should we?
As a result, the question that is continually raised
is whether we will be able to retain anesthesia
time in the future as payment methodologies change.
At the same moment that anesthesia time is being
debated, some in organized medicine have advocated
a change in payment to a single payment to providers
for a particular episode of care (episode case rate
payments), a blended payment based on both fee-for-service
and episode case rate payments or an expansion of
pay for performance (Davis K, Guterman S. Rewarding
excellence and efficiency in Medicare payments.
The Milbank Quarterly. 2007; 85(3):449-468.
Blackwell Publishing). Other payment methodologies
also are being considered. What they will mean for
anesthesia payment in the future remains unknown.
In response to these challenges, your ASA has been
proactive. We do not know if anesthesia time as
a separate payment element will last into the future,
but we have been preparing for the possibility that
it will not. In 2003 the ASA House of Delegates
authorized the president to appoint a task force
(TF) to study the relationship of anesthesiology’s
payment methodology to the RBRVS and to answer the
question, “Would a change to RBRVS methodology
offer a chance for improved payment?” The
TF produced a focused study of the RVG versus the
RBRVS methodology for anesthesia and studied the
ramifications of integration into the RBRVS under
Medicare. The TF looked at four RBRVS models: flat
fee based on an expanded anesthesia code set; time-based
using existing core expanded anesthesia code sets;
flat fee based on surgical CPT codes and average
time; and a building block method using E/M plus
intraservice value. All of these models could work,
but they all had some problems. In the flat fee
and average time models, academic practices would
suffer (since their cases are longer and more complex)
as would anesthesiologists working with slower surgeons.
In the other models that were considered, numerous
new codes would be required to determine values
based on the complexity of the case and type of
anesthesia. In all of the models, adjustments would
have to be made for multiple surgical procedures.
The TF concluded: Time may last forever, but anesthesia
time units probably will not; all the models for
integrating anesthesia into the RBRVS either do
not show much improvement or are unduly complex
and unfair to some; we should keep time as long
as possible; and ASA must be prepared with viable
alternatives when and if we lose anesthesia time
units. The findings of the TF were presented at
the 2004 ASA Annual Meeting.
The ASA Committee on Economics (COE) continues to
study health care literature regarding payment methodologies,
to explore new methods of paying for our services,
and continues the work of the original TF through
the COE Workgroup on Payment. Recently COE involved
the Certificate in Business Administration (CBA)
Program in the Alternative Payment Methodology Project.
We hope the additional input and brainstorming of
the CBA candidates will bring the additional insight
and creativity necessary to develop an alternative
payment methodology that will protect all anesthesiologists’
incomes in a fair and equitable manner.
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Karl
E. Becker, M.D., M.B.A., is Adjunct Professor
of Anesthesiology, University of Kansas School
of Medicine, Kansas University Medical Center
and Principal, Carruthers Group, Leawood, Kansas.
He is now retired from clinical practice. |
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Neal
H. Cohen, M.D., M.P.H., M.S., is Vice-Dean,
Professor of Anesthesia and Medicine, University
of California-San Francisco School of Medicine,
San Francisco, California. |
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