SCAI Opposes Multiple Procedure Payment Reduction for Diagnostic CV
September 14, 2012
Last week, SCAI transmitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the 2013 Medicare Physician Fee Schedule. The Society expressed vehement opposition to CMS’s proposal to apply the multiple procedure payment reduction (MPPR) to the technical component of many diagnostic cardiovascular services. SCAI believes the agency’s plan to achieve economic savings could actually impact patients’ outcomes while penalizing the most efficient physicians.
SCAI also commented on CMS’s approach to stratifying physicians by their specialty or subspecialty in analyses of cost and quality. CMS’s current plans are to compare physicians within groups based on their broad specialty, rather on the composition of the clinical services they deliver. SCAI believes this approach will lead to apples-to-oranges comparisons across physicians who share a specialty but provide more or less complicated services. For example, office-based cardiologists and procedurally focused cardiologists would occupy the same comparison group because both are cardiologists, but the proceduralists are disadvantaged because the services they bill for are almost certain to cost more.
SCAI also pointed out that, if implemented, the proposed rule’s risk adjustment methodology for cost assessment would likely lead some physicians to be unfairly labeled as over-utilizers simply because they treat a sicker group of patients.
Finally, in response to widely publicized plans to implement value-based modifiers as a means to promote quality and patient satisfaction, SCAI recommended limiting this action to large integrated (or integrating) health systems, where hospitals either employ the physicians or have ownership in physician practices because only larger systems can have the integrated information systems necessary to show “value” to payers.
SCAI’s comments were in large part echoed by the Alliance for Specialty Medicine.
What happens now? The 2013 Medicare Physician Fee Schedule Final Rule will be released in early November, at which time values for the new PCI, TAVR, and pVAD codes will be revealed. Be sure to watch for SCAI’s analysis of the Final Rule.