ACC Submits Comments on Proposed 2024 Medicare PFS and Hospital OPPS Rule

The ACC has submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2024 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) rule released in July.

In comments regarding the proposed 2024 Medicare Physician Fee Schedule, the ACC urged CMS to take steps to mitigate the proposed 3.36% reduction to the conversion factor, which would lower Medicare reimbursements across the board. In addition to addressing the conversion factor cuts in proposed rule, the College is working to ensure a consistent, stable future for physician reimbursement by supporting the Strengthening Medicare for Patients and Providers Act (H.R. 2474), which would provide a permanent, annual update to the Medicare Physician Fee Schedule equal to the increase in the Medicare Economic Index, allowing physicians to invest in their practices and implement new strategies to provide high-value care.

Other significant components of ACC’s feedback include:

  • Appropriate Use Criteria: The ACC supports the CMS proposal to pause the program and rescind current regulations, urging the agency to fully abandon the program. 
  • Split-Shared Billing: The ACC supports the CMS proposal to delay the change to only allow time to be the determining factor in which providers can bill for the service for another year. The College also implores the agency to permanently dispense with the proposed changes as medical decision-making, history and evaluation should always be recognized as the substantial component of a service and the continued one-year delays of this proposed change adds administrative burden to practices as they continually prepare for this significant change.   
  • Telemedicine Flexibility Extensions: The ACC supports the CMS proposal to extend many of the telehealth flexibilities enacted during the COVID-19 Public Health Emergency and argues for making certain components permanent.
  • Heart Failure Cost Measure: The ACC continues to raise concerns that due to the complexity and heterogeneity of this patient population, any cost measure for heart failure has the potential to create unintended consequences impacting the ability to provide guideline-directed care.
  • G2211 Office/Outpatient E/M Visit Complexity Add-on HCPCS Code: The ACC supports the concept of additional resources being provided to address patients that are outliers to those typically described in office visit valuations; however, the College feels this particular code needs to be more clearly defined to avoid overuse and abuse as well as liability of the provider to audits of the code. Should this code or some other version be enacted, the College believes the estimated utilization should be lowered dramatically to be in-line with historical examples of similar code implementations. This reduction in utilization estimate would lessen the reduction to the conversion factor. 
  • New/Revised CPT Code Valuations: The ACC supports the agency’s proposed acceptance of RVS Update Committee (RUC) values for the new Fractional Flow Reserve (FFR) Computed Tomography (CT) code, the 12 new programming and implantation codes for the Phrenic Nerve Stimulation system, the new intravascular lithotripsy (IVL) code, three of five new venography codes, and the PE inputs for 93297 and 93298, which are replacing code G2066 with national pricing. The College also addressed codes where CMS has not proposed accepting the RUC-recommended work relative value units including:
    • Venography codes for Venovenous Collaterals originating above and below the heart: The College’s comments state that these codes are being under-valued by the agency. The ACC also joined the Society for Cardiovascular Angiography and Interventions in meeting with CMS officials earlier this week to make this case directly.
    • Intraoperative Ultrasound: Four of five of these codes were significantly reduced in the agency’s proposed rule. In alignment with the Society of Thoracic Surgeons, the College’s comments point out the flawed methodology CMS used in arriving at their proposed values for these codes.

In comments regarding the proposed 2024 Hospital Outpatient Prospective Payment System rule, notable comments by the ACC include:

  • Cardiac Positron Emission Tomography (PET)/CT Studies: The ACC supports the American Society of Nuclear Cardiology in opposing changes to the ambulatory payment classifications (APCs) of PET/CT codes 78431 and 78432. The College urges CMS to create more narrow pay bands between APCs above $2,000 to avoid significant swings in reimbursement from year to year depending on variable claim data.
  • APC Complexity Adjustments: The ACC argues for reform to the complexity adjustment system so that important ancillary services such as FFR, intravascular ultrasound, and others will be more accessible to patients without a financial disincentive to the facilities performing the services.
  • Supervision by NPs, PAs and CNSs of Cardiac Rehabilitation (Rehab), Intensive Cardiac Rehab and Pulmonary Rehab Services Furnished to Outpatients: The ACC supports CMS proposals to implement these regulations mandated by ACC-championed legislation.
  • Expiration of Transitional Pass-Through Payment for IVL: The ACC urges CMS to address the six-month window beginning July 1, 2024, where no pass-through reimbursement will be available for IVL.

To support the College’s Medicare payment reform efforts, attend ACC Legislative Conference 2023, taking place Oct. 15-17 in Washington, DC, to hear from health policy experts about ACC’s priority advocacy issues and to ensure the voice of cardiology is heard on Capitol Hill. Learn more and register here.

Clinical Topics: COVID-19 Hub, Heart Failure and Cardiomyopathies, Noninvasive Imaging, Acute Heart Failure, Angiography, Echocardiography/Ultrasound, Nuclear Imaging

Keywords: Policy, Ultrasonography, Interventional, Lithotripsy, Surgeons, Office Visits, Cardiology, Telemedicine, Costs and Cost Analysis, Heart Failure, Fee Schedules, COVID-19, Medicaid, Phlebography, Feedback, Medicare, Fractional Flow Reserve, Myocardial, Current Procedural Terminology, Centers for Medicare and Medicaid Services, U.S., Outpatients, Healthcare Common Procedure Coding System, United States, ACC Advocacy

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