On September 10, the American Society of Anesthesiologists (ASA) submitted comprehensive comments to the Centers for Medicare & Medicaid Services (CMS) on the Proposed Rule for the 2019 Medicare Physician Fee Schedule and Quality Payment Program.
ASA comments reflected its interests in the Physician Fee Schedule, Quality Payment Program and a Request for Information on Out-of-Network billing.
Medicare Physician Fee Schedule (MPFS)
ASA supported the administration’s desire to reduce regulatory burden and to update rules and regulations that are dated and fail to reflect current practice. ASA therefore:
- Supported the reduction of documentation standards for Evaluation & Management (E/M) services
- Supported the reduction of documentation for alcohol and substance abuse assessment and intervention services (G-codes G0396 and G0397; creation of additional code)
- Supported the CMS valuation of CPT® Code 64405 and urged CMS to accept the proposal of numerous stakeholders on CPT® Code 95970
- Supported efforts to further develop and test bundled payments for Substance Abuse Disorder patients
In the same rule, ASA disagreed with the urgency that CMS had regarding the revised categorization and payment of E/M services from five distinct categories to just two category payments. ASA urged CMS to work with specialty societies and other stakeholders to ensure revisions to E/M payments are thorough and well-thought out before making any changes to the current schedule.
Quality Payment Program (QPP)
ASA advocated for a number of issues within the proposed 2019 Quality Payment Program rule that will enhance the role physician anesthesiologists play in delivering care and protecting patient safety. Foremost, ASA continues to support the opt-in for practices to report MIPS and earn a payment bonus. In addition, ASA:
- Advocated for the continued inclusion of MIPS 426 and MIPS 427 – two transfer of care measures in the anesthesiology quality measure set
- Supported the automatic scoring of facility-based eligible clinicians in the Cost and Quality components
- Recommended that CMS award bonus points to practices who will report to a registry for MIPS purposes but whose facility-based score will be used by CMS for their Quality and Cost MIPS components
- Encouraged CMS to publish Improvement Activities data validation materials annually for practices to begin documenting their activities early in the year
- Urged CMS that attention be paid to ensure that measures used in Advanced Alternative Payment Models (APMs) can meaningfully assess the contributions of specialists
ASA also provided comments on quality measure benchmarking, participant use of third-party intermediaries like the Anesthesia Quality Institute National Anesthesia Clinical Outcomes Registry (AQI NACOR) and proposals to rank certain MIPS and Qualified Clinical Data Registry (QCDR) measures.
Price Transparency – Out of Network Billing
ASA also submitted comments on the CMS Request for Information aimed at addressing Out-of-Network Billing. The comments explained that “surprise bills,” more accurately described as “surprise insurance gaps,” would disappear if insurance companies were forced to adhere to a “fair payment” in an out-of-network payment setting. Additionally, maintaining an adequate network for all providers and all services is the key to solving the problem. Specifically, the comments encouraged the following solutions:
Insurers must ensure that they have an adequate number of physicians from all areas of medicine in the plans they sell.
- Health insurance companies must provide fair payment for medical services.
- Insurance plans must be required to provide robust information to guide patients when selecting health insurance plans.
For additional information about out-of-network payment, please contact firstname.lastname@example.org.
As the medical specialty representing the recognized leaders in patient safety and quality, ASA is committed to working with CMS to promote policies that support high quality care in a fiscally sustainable manner. ASA is pleased to work with CMS to create a healthcare system that reduces administrative burden on practicing physicians and is forward thinking in the development of innovative solutions to overcome the challenges facing clinicians, patients and the Medicare system overall.
ASA expects that CMS will issue its final rule in late October or early November 2018. Changes to the fee schedule and the Quality Payment Program will be implemented on January 1, 2019. Please check back with the ASA later this year for further information.
To review the Proposed Rule, click here
To review ASA’s Comments, click here