After reviewing the proposed 2015 Physician Fee Schedule and hospital outpatient rules that were released in July, the ACC has submitted two comment letters to the Centers for Medicare and Medicaid Services (CMS) that detail strengths and weaknesses of the cardiovascular-related proposals. Read the physician and hospital proposed rule comments in their entirety.

Physician Fee Schedule

The Physician Fee Schedule proposed rule indicates that physicians will see no change in payment for the first three months of 2015 due to the latest Sustainable Growth Rate (SGR) patch. However, the SGR will take effect April 1, 2015, unless Congress once again intervenes. At that time physicians would face a 20.9 percent cut as a result of the legally mandated SGR. As in previous years, the ACC continues to fight to avoid cuts to Medicare payment for cardiovascular services. Aside from the across-the-board cuts associated with the SGR, CMS estimates that the physician rule will increase payments by 1 percent to cardiologists from 2014 to 2015. This estimate is based on typical practice and can vary widely depending on the mix of services provided in a practice. View the impact on several key cardiology services.

Payment Proposals

• Do not finalize the proposal to migrate all 10- and 90-day global package services to 0-day global packages.
• Work with societies to collect two years of data on the number and level of postoperative services to inform future policymaking on global package services.
• Do not finalize a proposal to review services with more than $10 million in annual spending as potentially misvalued.
• Provide increased transparency about code value decision-making.
• Adopt the American Medical Association proposal to better align rulemaking with the CPT code development and valuation calendar.
• Develop a fair, objective and consistently applied appeals process to address disputed code values.
• Accept the RUC recommendation to remove the film supply and equipment items associated with film technology.
• Be cautious and critical of conclusions from the RVU validation projects by the Urban Institute and RAND Corporation.
• Adopt a Healthcare Common Procedure Coding System (HCPCS) code to capture data on services in off-campus provider-based hospital departments only if no other way can be found collect data on services provided in off-campus provider-based hospital departments.
• Adopt the newly created chronic care management CPT code and RVUs.
• Adopt the proposal to remove employment requirements for services furnished “Incident to” Rural Health Clinics and Federally Qualified Health Center visits.
• Publish and solicit feedback on draft methodologies to use identifiable data to evaluate payment models tested by the Center for Medicare and Medicaid Innovation.  

Quality and Value Proposals

• Proceed cautiously with public reporting of individual eligible providers’ performance data.
• Implement changes to the Physician Quality Reporting System (PQRS) incrementally for existing and expanded eligible professional groups.
• Do not finalize the proposal to require reporting of at least two cross-cutting measures for satisfactory PQRS reporting in 2015.
• Do not finalize the proposal to require a Qualified Clinical Data Registry to possess at least three outcome measures. Maintain the current standard of one outcome measure for 2015 until more meaningful outcome measures can be developed across specialties.
• Proceed cautiously with public reporting of individual eligible providers’ performance data, and focus on centralizing public reporting efforts through the Physician Compare website.
• Do not finalize proposal to double the amount of payment at risk from the Value-Based Payment Modifier from two percent to four percent for the calendar year (CY) 2017 payment period.

Hospital Outpatient Prospective Payment System (HOPPS)

CMS proposes to update the HOPPS market basket by 2.1 percent for CY 2015. The increase is based on the projected hospital market basket increase of 2.7 percent minus both a 0.4 percentage point adjustment for multi-factor productivity and a 0.2 percentage point adjustment required by law.

Highlights of ACC’s comments include:

• Monitoring the implementation of the comprehensive Ambulatory Payment Classifications to ensure that accurate costs and resource utilization are captured for rate setting.
• Support of the complexity adjustment for certain add-on services provided with a primary procedure.
• Continued opposition against the expansion of the packaging policy to include ancillary services, even under the proposed threshold.
• Support of the proposed revision to eliminate the requirement of  physician certification of hospital inpatient services other than psychiatric inpatient services in all cases except high-cost and outlier stays.
• Support adoption of a HCPCS code to capture data on services in off-campus provider-based hospital departments only if no other way can be found collect data on services provided in off-campus provider-based hospital departments.
• Support of the retirement of topped-out measures including OP-4: Aspirin at Arrival (NQF # 0286) from the Hospital Outpatient Quality Reporting Program, as long as CMS implements a method to keep these measures in “reserve” status for efficient re-introduction into the Program if necessary.

Keywords: Outcome Assessment, Health Care, Rural Health, Healthcare Common Procedure Coding System, Employment, Medicaid, Centers for Medicare and Medicaid Services, U.S., Registries, Outpatients, Hospital Departments, Fee Schedules, Retirement, Medicare, Certification, Current Procedural Terminology, Prospective Payment System

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