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Recently, SVS submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) Calendar Year (CY) 2015 Medicare Physician Fee Schedule (MPFS) Proposed Rule. The following are some of the issues that SVS addressed:
Improving the valuation and coding of the global package
The most controversial issue that SVS commented on was the proposal to transition all 10- and 90-day global bundles to 0-day global codes by 2018, with medically reasonable and necessary visits billed separately during the pre- and postoperative periods outside the day for surgical procedures. SVS opposed this proposal along with many other surgical societies.
Some of the reasons for opposition included:
▶ CMS has no idea how to implement this change in policy;
▶ The agency’s concerns regarding the accuracy of payments would not be addressed by this proposal;
▶ Patients would be subject to extra co-pays, particularly for postoperative care and additional administrative costs would be incurred for the extra billing;
▶ New values would need to be created for postoperative care because not all these procedures have separate codes;
▶ Many other services are being bundled – this creates unbundling for surgical care which is inconsistent with what CMS is proposing in other areas.
Using hospital outpatient prospective payment system (OPPS) and ambulatory surgery center (ASC) data in developing practice expense (PE) relative value units (RVU)
SVS thanked CMS for withdrawing the nonfacility cap proposal that was in the CY 2014 MPFS Proposed Rule and for acknowledging that “the comparison of OPPS or ASC payment amounts to PFS payment amounts for particular procedures is not the most appropriate or effective approach to ensuring that PFS payment rates are based on accurate cost assumptions.”
SVS continues to oppose using OPPS cost data for potential revisions of PFS PE methodology as there are many differences, which include using an averaging mechanism that undervalues high-cost items and overvalues low-cost items versus creating codes on actual costs. This would be a disservice to patients on many levels and not provide true costs for the work provided.
Abdominal aortic aneurysm (AAA) ultrasound screening – G0389
SVS members and staff met with CMS staff in May regarding AAA ultrasound screening reimbursement. G0389 had an undervalued Technical Component of $36.90, which was equivalent to retroperitoneal ultrasound that uses different equipment and takes less time to perform.
The low reimbursement also created a disincentive to provide this life-saving screening. CMS proposed maintaining the work RVU and reverting back to the same PE RVU used in 2013, which is now $80.24; SVS strongly agreed with this proposal.
Valuing new, revised and potentially misvalued codes
CMS proposed a new timeline and process for the publication and implementation of changes to physician codes which SVS supports as a more rational approach.
The current process announces proposed changes at the beginning of November and implements these changes on Jan. 1 of the following year. This does not allow adequate public comment or sufficient time for physicians to prepare for the changes, including a reasonable evaluation of how the revisions might impact their practices and patients.
To accommodate the proposed process, SVS recommended that the meeting structure for both the Current Procedural Terminology (CPT) Panel and Relative Value Update Committee (RUC) be maintained, but the workflow should be shifted to review the commonly performed services at the May CPT/October RUC and the October CPT/January RUC in order to publish the proposed values for new, revised, and misvalued codes in the July MPFS Proposed Rules.
In addition, SVS recommended that the new timeline and process be delayed until 2017 to allow sufficient time to implement the revised process.
To download a PDF of additional comments on these and other issues contained in the 2015 MPFS Proposed rule, please visit vsweb.org/2015MPFS.
Recently, SVS submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) Calendar Year (CY) 2015 Medicare Physician Fee Schedule (MPFS) Proposed Rule. The following are some of the issues that SVS addressed:
Improving the valuation and coding of the global package
The most controversial issue that SVS commented on was the proposal to transition all 10- and 90-day global bundles to 0-day global codes by 2018, with medically reasonable and necessary visits billed separately during the pre- and postoperative periods outside the day for surgical procedures. SVS opposed this proposal along with many other surgical societies.
Some of the reasons for opposition included:
▶ CMS has no idea how to implement this change in policy;
▶ The agency’s concerns regarding the accuracy of payments would not be addressed by this proposal;
▶ Patients would be subject to extra co-pays, particularly for postoperative care and additional administrative costs would be incurred for the extra billing;
▶ New values would need to be created for postoperative care because not all these procedures have separate codes;
▶ Many other services are being bundled – this creates unbundling for surgical care which is inconsistent with what CMS is proposing in other areas.
Using hospital outpatient prospective payment system (OPPS) and ambulatory surgery center (ASC) data in developing practice expense (PE) relative value units (RVU)
SVS thanked CMS for withdrawing the nonfacility cap proposal that was in the CY 2014 MPFS Proposed Rule and for acknowledging that “the comparison of OPPS or ASC payment amounts to PFS payment amounts for particular procedures is not the most appropriate or effective approach to ensuring that PFS payment rates are based on accurate cost assumptions.”
SVS continues to oppose using OPPS cost data for potential revisions of PFS PE methodology as there are many differences, which include using an averaging mechanism that undervalues high-cost items and overvalues low-cost items versus creating codes on actual costs. This would be a disservice to patients on many levels and not provide true costs for the work provided.
Abdominal aortic aneurysm (AAA) ultrasound screening – G0389
SVS members and staff met with CMS staff in May regarding AAA ultrasound screening reimbursement. G0389 had an undervalued Technical Component of $36.90, which was equivalent to retroperitoneal ultrasound that uses different equipment and takes less time to perform.
The low reimbursement also created a disincentive to provide this life-saving screening. CMS proposed maintaining the work RVU and reverting back to the same PE RVU used in 2013, which is now $80.24; SVS strongly agreed with this proposal.
Valuing new, revised and potentially misvalued codes
CMS proposed a new timeline and process for the publication and implementation of changes to physician codes which SVS supports as a more rational approach.
The current process announces proposed changes at the beginning of November and implements these changes on Jan. 1 of the following year. This does not allow adequate public comment or sufficient time for physicians to prepare for the changes, including a reasonable evaluation of how the revisions might impact their practices and patients.
To accommodate the proposed process, SVS recommended that the meeting structure for both the Current Procedural Terminology (CPT) Panel and Relative Value Update Committee (RUC) be maintained, but the workflow should be shifted to review the commonly performed services at the May CPT/October RUC and the October CPT/January RUC in order to publish the proposed values for new, revised, and misvalued codes in the July MPFS Proposed Rules.
In addition, SVS recommended that the new timeline and process be delayed until 2017 to allow sufficient time to implement the revised process.
To download a PDF of additional comments on these and other issues contained in the 2015 MPFS Proposed rule, please visit vsweb.org/2015MPFS.
Recently, SVS submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) Calendar Year (CY) 2015 Medicare Physician Fee Schedule (MPFS) Proposed Rule. The following are some of the issues that SVS addressed:
Improving the valuation and coding of the global package
The most controversial issue that SVS commented on was the proposal to transition all 10- and 90-day global bundles to 0-day global codes by 2018, with medically reasonable and necessary visits billed separately during the pre- and postoperative periods outside the day for surgical procedures. SVS opposed this proposal along with many other surgical societies.
Some of the reasons for opposition included:
▶ CMS has no idea how to implement this change in policy;
▶ The agency’s concerns regarding the accuracy of payments would not be addressed by this proposal;
▶ Patients would be subject to extra co-pays, particularly for postoperative care and additional administrative costs would be incurred for the extra billing;
▶ New values would need to be created for postoperative care because not all these procedures have separate codes;
▶ Many other services are being bundled – this creates unbundling for surgical care which is inconsistent with what CMS is proposing in other areas.
Using hospital outpatient prospective payment system (OPPS) and ambulatory surgery center (ASC) data in developing practice expense (PE) relative value units (RVU)
SVS thanked CMS for withdrawing the nonfacility cap proposal that was in the CY 2014 MPFS Proposed Rule and for acknowledging that “the comparison of OPPS or ASC payment amounts to PFS payment amounts for particular procedures is not the most appropriate or effective approach to ensuring that PFS payment rates are based on accurate cost assumptions.”
SVS continues to oppose using OPPS cost data for potential revisions of PFS PE methodology as there are many differences, which include using an averaging mechanism that undervalues high-cost items and overvalues low-cost items versus creating codes on actual costs. This would be a disservice to patients on many levels and not provide true costs for the work provided.
Abdominal aortic aneurysm (AAA) ultrasound screening – G0389
SVS members and staff met with CMS staff in May regarding AAA ultrasound screening reimbursement. G0389 had an undervalued Technical Component of $36.90, which was equivalent to retroperitoneal ultrasound that uses different equipment and takes less time to perform.
The low reimbursement also created a disincentive to provide this life-saving screening. CMS proposed maintaining the work RVU and reverting back to the same PE RVU used in 2013, which is now $80.24; SVS strongly agreed with this proposal.
Valuing new, revised and potentially misvalued codes
CMS proposed a new timeline and process for the publication and implementation of changes to physician codes which SVS supports as a more rational approach.
The current process announces proposed changes at the beginning of November and implements these changes on Jan. 1 of the following year. This does not allow adequate public comment or sufficient time for physicians to prepare for the changes, including a reasonable evaluation of how the revisions might impact their practices and patients.
To accommodate the proposed process, SVS recommended that the meeting structure for both the Current Procedural Terminology (CPT) Panel and Relative Value Update Committee (RUC) be maintained, but the workflow should be shifted to review the commonly performed services at the May CPT/October RUC and the October CPT/January RUC in order to publish the proposed values for new, revised, and misvalued codes in the July MPFS Proposed Rules.
In addition, SVS recommended that the new timeline and process be delayed until 2017 to allow sufficient time to implement the revised process.
To download a PDF of additional comments on these and other issues contained in the 2015 MPFS Proposed rule, please visit vsweb.org/2015MPFS.