Positive Progress on the Medicare Physician Fee Schedule
Something positive actually happened at the Department of Health and Human Services for cardiologists on Friday!
The Centers for Medicare and Medicaid Services (CMS) on Friday released a technical correction to the 2010 Medicare Physician Fee Schedule, which results in significant payment increases for myocardial perfusion imaging (MPI) codes, cardiac CT codes, and cardiac catheterization codes, retroactive to Jan. 1, 2010. The correction notice also includes a minor increase in the Medicare conversion factor (from 36.066 to 36.0791) effective June through December 2010. Our colleagues at ASNC deserve major credit here for their technical work, persistence, and serving as the lead agency in pressuring CMS to correct their RUC-related errors on the nuclear codes.
However, this is not the BIG FIX needed to protect private practice, but it is a positive step for sure. The danger here is we don’t want Congress to think this will fix the problem. This will NOT stabilize private practice, and does nothing at all for ECHO, consults, or most practice expense cuts. Half of cardiology private practices have already sold their practices to employment and are now employees -- this positive step in the right direction is too late for them. But those still considering selling their practices to survive may see this partial step as a good sign. All in all, this definitely helps.
The corrections the Secretary approved to MPI and CT codes address errors made in incorporating RUC recommendations on direct practice expenses (e.g., medical supplies, equipment time) for these services. The errors included incorrect practice expense values for CPT codes 75571-75574 and 78451-78454. For example, the corrected national average payment for 78452 (SPECT MPI, multiple) is $439, compared to the $379 published in the November Final Rule.
The correction notice also includes changes to malpractice RVUs for cardiac catheterization services. CMS agreed with ACC, SCAI, and the AMA that cardiac cath services should be assigned malpractice RVUs based on the higher surgical risk factor. However, the published RVUs and payment rates did not correctly reflect that policy change. With this notice, CMS has corrected its error. The payment changes -- for example, an increase from $235 to $253 for 93510-26 (Left heart catheterization, professional component) -- reflect the higher risk associated with invasive procedures.
The ACC has prepared a chart outlining the specific corrections (.xls).
The ACC continues to apply pressure to CMS to address the other imaging cuts included in the 2010 Medicare rule. Most importantly, we continue to press for a phase-in of the bundled nuclear codes and an approach to restoring echo and other services through adherence to appropriate use criteria -- we are working closely in repeated visits with members of Congress and CMS to help them understand the extent of the cuts, their impacts on practices and the need for a formal policy that phases in cuts of a certain magnitude over time. In the meantime, stay tuned for more information as it relates to notifying private insurance companies of these new corrections, since they typically track Medicare payments.
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