Recently, the ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding aspects of the 2014 physician fee schedule final rule. Critiques were made of changes CMS made to work and practice expense submissions for several services. The comments recommend restoration of work values for transcatheter aortic valve replacement, patent ductus arteriosus closure, and certain intravascular stent services, as well as practice expense values for selective catheter placement, intravascular stents, and extracranial duplex ultrasound studies. Any changes to these inputs will be reflected in the 2015 final rule this November. Comments were also provided supporting ongoing proposals to pay for non-face-to-face chronic care management services and opposing further efforts to cap practice expense for services provided in the nonfacility setting at facility rates.

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