We’re still fiercely fighting the 2010 Medicare Physician Fee Schedule (Payment Rule), and the new one has been issued in draft. The comment period runs through the summer, with the final Rule due out in November.

Let me summarize by saying it is what we expected. No new significant cuts, but no reversal of last year. We weighed in early on the Stark issue and CMS has taken our recommendation to limit application of the new disclosure requirement to the imaging modalities specified in Affordable Care Act even though there was discretion to expand to all imaging. There are some elements of how CMS is proposing to implement this that we will want to try to get changed, but limiting the scope of it is a big win.

We're still reeling from the unintended but horrific consequences of last year’s Rule -- it killed off more than 50% of the private practice of cardiology in the US. Done. Gone. Not likely ever to return from hospital employment. And the remaining practices are not doing well.

See the all-member alert for the specifics of the 2011 Rule.

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