On Tuesday, September 2, ASA submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on a number of issues included in the Proposed Rule for the 2015 Medicare Physician Fee Schedule. This proposed rule outlines proposed changes to policies and payment rates for services rendered on and after January 1, 2015.
ASA thanked CMS for proposing to revert back to the 2013 values that resulted from the ASA-led survey of codes for interlaminar epidural injections (CPT® codes 62310, 62311, 62318 and 62319). ASA also recognized that CMS placed the codes back onto the “misvalued codes list” to facilitate obtaining more information in regard to valuing the injections. The Society, however, expressed concern that bundling the imaging guidance into the injection codes and prohibiting the separate billing of imaging guidance in conjunction with these codes may be premature. Nevertheless, ASA will work via the CPT (Current Procedural Terminology) and RUC (Relative Value Scale Update Committee) processes to ensure that the codes accurately describe the services performed and that the values accurately capture all the resources and risks associated with providing the care.
ASA supported CMS’s proposal to revise the definition of “colorectal cancer screening tests” to include anesthesia that is separately furnished in conjunction with screening colonoscopies. In finalizing this proposal, ASA also supported the following:
- As an essential benefit, Medicare should pay the anesthesia provider for the service; payment should not be conditioned on the presence of other specified diseases, conditions, or situations.
- Payment for this anesthesia service should be determined in the same manner as any other anesthetic, i.e., the “base + time” methodology.
In addition, ASA encouraged CMS to apply the essential benefits payment provisions when a screening endoscopy turns diagnostic or therapeutic - if polyps are discovered and removed during the encounter.
In regards to the Physician Quality Reporting System (PQRS), ASA urged CMS to continue the claimed-based reporting option past 2015. ASA supports the continued use of the Claims-Based Measure-Applicability Validation (MAV) process for those eligible professionals (EPs) who have zero measures to report.
ASA proposed that CMS maintain the current one outcome measure requirement for an EP to report via the Qualified Clinical Data Registry (QCDR) option. ASA requested that CMS delay the implementation requirement of reporting three outcome measures until sufficient data is collected and analyzed to ensure that physician anesthesiologists and other EPs would be able to report on more than one outcome measure.
ASA objected to the proposed removal of PQRS #30: Timing of Prophylactic Antibiotic – Administering Physician and similar measures related to perioperative care. ASA also proposed that CMS provide a three-year advanced notice to measure stewards, EPs, and stakeholders potentially affected by the removal of a measure.
For the Value-Based Payment Modifier and Physician Feedback Program, ASA expressed concern with the proposal to increase the amount at risk from 2% of allowed charges in the CY2016 payment adjustment period to 4% for the CY2017 payment adjustment period. ASA recommended no increase to the amount at risk for 2017.
Read ASA’s comments to CMS on the proposed 2015 Medicare Physician Fee Schedule.
Review the proposed 2015 Medicare Physician Fee Schedule.