Urgent Changes Needed for Medicare Physician Fee Schedule

On behalf of its more than 750 member companies, HBMA submitted comments to CMS and the Department of Health and Human Services on the Notice of Proposed Rulemaking (NPRM) regarding the Medicare Physician Fee Schedule as published in the July 19, 2011 Federal Register. The  proposed rules are of great concern to healthcare providers and the HBMA membership base as a whole, so the association’s government relations committee felt compelled to address this important matter.

The full comments to CMS can be found here.While it certainly contains extensive information, the crucial point is that HBMA believes the proposed Medicare Physician Fee Schedule as published will have a devastating impact on physician income, and ultimately, access to care for Medicare beneficiaries. Billing companies have both a unique perspective and substantial, current experience in these areas, with the association’s member companies currently processing in excess of 350 million claims annually, an estimated one third of all claims submitted on behalf of physicians.

A short summary of the parts of the proposed rule addressed by HBMA is listed below:

1. SGR-related reduction to the Medicare Conversion Factor

A. CMS should convene a workgroup of representatives from the provider community, medical billing and compliance professionals to develop a more administratively reasonable, cost efficient and compliant mechanism for reprocessing under/over-paid claims, should there be events similar to the ones that occurred in the past and in 2010 – 2011.

B. If similar SGR-related events occur in the future, CMS should advise Congress that they should also appropriate a supplemental, “reprocessing payment” for providers and Medicare contractors, perhaps paid on a per-claim basis, to offset the burdensome, unfunded mandate created by legislative delay.

2. Quality Reporting Initiatives – Physician Quality Reporting System (PQRS)

A. Despite well-known budget challenges, CMS needs to investigate how PQRS incentives might be made more financially relevant.

B. Registry options should permit and support multiple pathways/formats.

C. CMS should solicit further formal (NPRM) or, at least, informal input, from interested parties before adopting final rules and/or policies.

3. Expansion of the Multiple Procedure Payment Reduction (MPPR)

A. CMS should withdraw this recommendation as it relates to the PC of currently identified imaging procedures until such time as there is research data to support the underlying assumption or reduce the reduction amount from CMS 50% to the figures identified in the JACR study.

B. Any consideration of expansion of the MPPR policy to the professional component of diagnostic testing and the technical component of other diagnostic modalities or procedures should be suspended until such time as there is research data to support the underlying assumption.

C. CMS should provide specific clarification of the definitions applicable to the technical and professional components.

4. Bundled Payments

A. This proposed rule should be rescinded until such time as the implantation is feasible and attainable and that physicians can reasonably comply with the requirement.

5. Medicare Coverage and Payment of the Annual Wellness Visit

A. CMS should suspend application of the new policy until deficiencies, if any, in the current AWV requirements that would necessitate implementing the Health Risk Assessment can be quantified and validated.

B. CMS should adjust payment for the AWV to accurately reflect the more comprehensive services required.

For additional details on these recommendations or other key legislative issues affecting HBMA members, please visit the government news resource on the HBMA website.