July 02, 2009
CMS Releases Proposed 2010 Medicare Physician Fee Schedule
The Centers for Medicare and Medicaid Services (CMS) has released
the proposed 2010 Medicare Physician Fee Schedule. ASA is reviewing
and analyzing the 1128-page rule, and will provide membership with
additional information about proposed changes. Comments on the rule
will be due by August 31 and filed by ASA.
The proposed rule includes a number of key provisions relevant to anesthesiology:
- Medicare Anesthesiology Teaching Rule Payment Update
– Beginning January 2010, CMS will provide full Medicare payment when a
teaching anesthesiologist oversees anesthesiology residents on two
overlapping cases, consistent with the Medicare Anesthesiology Teaching
Funding Restoration Act of 2007, which became law last year.
- Removal of Physician-Administered Drugs for Purposes of Computing Update – CMS
is proposing to remove physician-administered drugs from the definition
of “physician services” for purposes of computing the physician update
formula. While the proposal will not change the projected update for
services during CY 2010 unless Congress acts this year, CMS projects
that it would reduce the number of years in which physicians are
projected to experience a negative update.
- Physician Payment Update – Under
the proposed rule, and consistent with current law, CMS plans to
implement the slated rate reduction of -21.5% for CY 2010. Since
2003, however, Congress has acted to avert significant reductions in
Medicare physician payments, with the latest of these interventions
occurring last July via the Medicare Improvements for Patients and
Providers Act of 2008 (MIPPA). MIPPA provided physicians with a 0.5%
update for the remainder of 2008 followed by a 1.1% update through
December 31, 2009, thereby preventing what was at the time a projected
10.6% Medicare payment reduction.
- Physician Payment Refinements to Practice Expense (PE) – CMS
proposes several changes intended to refine Medicare payments to
physicians, which are expected to increase payment rates for primary
care and other physicians, including anesthesiologists. The proposals
include an update to the PE component of physician fees. For 2010, CMS
is proposing to include data about physicians’ practice costs from a
new survey, the Physician Practice Information Survey (PPIS), designed
and conducted by the American Medical Association (AMA) and over 60
medical specialty societies including ASA.
- Physician Quality Reporting Initiative (PQRI) –
For 2010, participants may earn an incentive payment of 2.0% of the
eligible professional’s estimated total allowed charges for covered PFS
services under Medicare Part B provided during the reporting period.
The incentive program generally operates on a calendar year basis. For
the CY 2010 PQRI, there are a number of proposed reporting options and
reporting periods available. Some options require data to be submitted
by December 31, 2010. However, data reported through registries would
not be due to CMS until 2011. Key changes for CY 2010 include:
inclusion of the Perioperative Temperature Management measure, which
would provide a third measure for anesthesiologists (including Measures
30 (Timing of Prophylactic Antibiotics) and 76 (Prevention of
Catheter-Related Bloodstream Infections: Central Venous Catheter
provisions of MIPPA that would enable group practices to qualify for a
2010 PQRI incentive payment based on a determination at the group
practice level, rather than at the individual EP level, that the group
practice has satisfactorily reported data on PQRI quality measures;
an electronic health record (EHR)-based reporting mechanism to promote
the adoption and use of EHRs and to provide both eligible professionals
and CMS with experience on EHR-based quality reporting.
members should be ready to participate by submitting comment letters to
CMS when called upon. More information will be provided in the coming
In the meantime, if you have
specific concerns or knowledge about key portions of the rule, and
would like input to be considered when ASA crafts its comments to CMS,
please send an email to firstname.lastname@example.org, subject line: 2010 proposed rule.