On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) released the proposed 2019 Medicare Physician Fee Schedule and Quality Payment Program rules with an opportunity for public comments and feedback.
The proposal includes major changes to the Medicare physician fee schedule (PFS) and other Medicare Part B payment policies. Per CMS, this is to ensure that payment systems reflect changes in medical practice and the relative value of services provided. Click here read the entire CMS proposed rule.
What does this mean for you?
A preliminary review indicates that CMS proposes to have supplies and equipment inputs for all office procedures repriced. The methodology utilized to determine the new supply/equipment pricing is not completely clear from the proposed rule. This new pricing, if adopted as proposed by CMS could drastically alter the direct practice expense inputs utilized to calculate payments for many office-based procedures.
For example, there are substantial decreases for atherectomy devices and covered stents used in the SFA atherectomy and stent (CPT code 37227). These proposed changes would equate to more than a $4,000 reduction (a >30% reduction) in direct costs inputs used to calculate payments for CPT code 37227. The exact amount of the change in payment will be based on calculations that will be made by CMS to adjust for expected utilization rates. It would be expected based upon this proposed rule that drastic changes to office-based procedure payment would result. CMS proposes to phase the changes in over a 3-year period. Click here to learn more.
What can you do?
Join OEIS today! – OEIS is the ONLY voice dedicated to office based interventional and vascular care. OEIS also provides members with information and advocacy that is vital to you and your practice. Learn more.
Urge your partners and colleagues to join OEIS. The larger we are, the louder our voice!
Join the CardioVascular Coalition (CVC). The CVC is comprised of national organizations who came together to improve awareness and prevention of peripheral artery disease (PAD), reduce geographic disparities in access to care and secure high-quality, cost-effective interventional treatment across America. Learn more.
Submit a comment to CMS before September 10, 2018.
Key discussion points:
The methodology employed in determining the new supply and equipment values is not transparent and deviates from the well-established process of invoice submission to substantiate supply/equipment values.
Many of the new supply values are well below what small office-based practices can purchase the supplies for. If adopted, the new supply values will lead to an inability of small practices to offer office-based procedures, thereby pushing patients to the hospital setting for their care. This will result in increased costs for patients and decreased access to care, especially in rural areas.
CMS should adhere to its previous transparent methodology for updating supply and equipment costs.
Submitting a comment:
To be assured of consideration, all comments must be received at one of the addresses provided below, no later than 5:00 pm on September 10, 2018. Please allow sufficient time for mailed comments to be received before the close of the comment period. Click here to view sample comments.