On Aug. 29, the ACC submitted comments on the 2012 Physician Fee Schedule proposed rule for Medicare.  This rule covered a wide range of policy areas.  While this rule covers payment rates for next year, we didn’t see any disastrous surprises like we did in the 2010 rule that caused half of our private practice members to sell off their practices to become employees, mainly of hospitals.  ACC comments on this year’s rule included the following:

• We opposed the Centers for Medicare and Medicaid Services’ (CMS) efforts to reduce payment for the technical component of imaging services provided by the same physician on the same day.  CMS considers expanding this policy to all services in the future, which we also opposed.
• We strongly encouraged CMS to propose changes in payment rates to existing services to avoid the debacle that was caused when payment rates for SPECT MPI were found to be incorrect in 2010.
• We strongly discouraged CMS to implement a penalty for not participating in the Physician Quality Reporting System (PQRS, formerly PQRI) in 2013 by adjusting payment in 2015.  We believe Congress intended this to be based on 2015 participation.

We supported the notion that cardiology groups should be compared against each other in public reporting programs and in payment adjustments, rather than comparing individual cardiologists to primary care physicians.  

For more background, a summary of the proposed rule is available on CardioSource. This year’s rule may be nothing compared to the damage that could very likely occur in the chaos around the Joint Special Committee $1.5 trillion cut. The SGRrrr could kick in as a 31 percent cut to docs Jan 1!

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