ACC Submits Comments on CMS 2018 Physician Fee Schedule Proposed Rule

On Sept. 1, ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the proposed 2018 Medicare Physician Fee Schedule and related policies included in the proposed rule.

The ACC's comment letter specifically addresses proposed changes to the new appropriate use criteria (AUC) requirement for advanced imaging services (i.e., SPECT MPI, CT and MR), as well as changes to malpractice and practice expense components of the fee schedule, and recommendations regarding work relative value units for specific codes, payment rates for services provided by off-campus provider-based departments, quality and value program adjustments and reporting, and patient relationship codes to be used in quality reporting. The comments also touch on the implementation of new patient relationship codes aimed at improving cost measurement attribution.

"The ACC emphasizes the importance of meaningfully piloting patient relationship modifiers while thoroughly educating clinicians and their practice staff. Through this testing, CMS should determine whether clinicians and practice staff understand how to properly utilize these codes and categories, and whether their use poses interruptions to the clinical workflow. CMS should also determine whether EHR vendors can implement these codes and categories and develop necessary software upgrades within the given timeline," writes ACC President Mary Norine Walsh, MD, FACC. "CMS should take the feedback collected during this pilot period to make any necessary adjustments to the categories and codes themselves to ensure their accuracy, minimize administrative burden, and avoid unintended consequences."

Under the proposed rule, physicians would see a less than 0.1 percent conversion factor payment increase on Jan. 1, 2018. CMS estimates that the physician rule will decrease payments to cardiologists by 2 percent from 2017 to 2018. This estimate predicts a 1 percent reduction to changes in practice expense and a 1 percent reduction to changes in malpractice expense. It is based on the entire cardiology profession and can vary widely depending on the mix of services provided in a practice. Additionally, the start date for the new AUC requirement mandating that ordering professionals consult with AUC through a qualified clinical decision support mechanism (CDSM) would be delayed from Jan. 1 2018 to Jan. 1, 2019. The proposed rule would also reduce payment rates for certain items and services furnished by non-grandfathered off-campus hospital provider-based departments from 50 percent of the Hospital Outpatient Prospective Payment System to 25 percent and implement a request for information regarding potential changes to regulations to relieve administrative burdens, among other things.

The College will continue to advocate for thorough and ongoing educational opportunities and resources for clinicians and hospital administrators to ensure the smooth implementation of these proposed practice changes. ACC Advocacy staff are diligently monitoring new developments to this proposed rule. Get the latest information through the Advocate newsletter and @Cardiology on Twitter. Read the full comment letter here. Read highlights from the proposed rule here.


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