Letter to Congress
August 6, 2009
The undersigned organizations representing more than 750,000 physician and other health care professionals urge your support of Centers for Medicare and Medicaid Services’ (CMS) proposal, as published in the July 13, 2009 Federal Register, to update the Practice Expense (PE) component of the Medicare physician fee schedule with data from the recently concluded Physician Practice Information (PPI) Survey. CMS is accepting comments until August 31st and will issue a final rule in early November.
Notwithstanding the Congressional sign-on letter of Rep. Charles Gonzalez and Rep. Mike Rogers, we urge you to support CMS’s current efforts to update PE values for the following reasons:
- The pending CMS proposal includes the most current and accurate data to determine practice expense (PE) payments for all Medicare Part B providers. For most specialties, CMS is using practice cost data from 1995-1999 which clearly does not accurately capture the costs practices face today.
- Since 2004, MedPAC and GAO have been calling for CMS to update its practice expense data. The PPI survey responds to this request.
- In 2005, CMS accepted updated practice expense data for some specialties but not all providers. Because of budget neutrality, this led to a shift of payment into some specialties at the expense of all other providers. The proposed rule will correct payment imbalance because it implements data that was concurrently and uniformly collected.
- The methodologically rigorous survey process had broad support. It was supported by 52 specialties all of whom had input into the design, testing and implementation of the survey. The entire data process was overseen, according to CMS’ strict criteria for the gathering and submission of this type of PE survey data. Data which did not meet criteria was excluded, as were response outliers or responses that were statistically unacceptable. An independent contractor corroborated the results and recommended that CMS use the data.
The use of the new PE survey data will improve payment accuracy and correct significant inequities, which are goals shared by Congress, CMS, MedPAC, and the Administration. We support this objective and support the CMS proposal that will uniformly, fairly, and accurately update Medicare practice expense (PE) payments.
American Academy of Dermatology
American Academy of Family Physicians
American Academy of Neurology
American Academy of Neurological Surgeons
American Academy Ophthalmology
American Academy of Orthopaedic Surgeons
American Academy of Otolaryngology-Head and Neck Surgery
American Academy of Pediatrics
American College of Emergency Physicians
American College of Physicians
American College of Obstetricians and Gynecologists
American College of Surgeons
American Optometric Association
American Occupational Therapy Association
American Physical Therapy Association
American Society of Anesthesiologists
American Society of Cataract and Refractive Surgery
American Society of Plastic Surgeons
Congress of Neurological Surgeons
Infectious Diseases Society of America
North American Spine Society