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    Medicare 'adjustments' draw concern from American Urological Association

    Some changes lauded; rethink others, AUA urges CMS


    Bob Gatty
    Washington—The Centers for Medicare & Medicaid Services is in the process of finalizing proposed Medicare policies and payment rate changes for health care providers that would have significant impact on many urology practices.

    This month, the agency will complete its review of comments submitted regarding the adjustments, including a 17-page analysis submitted Aug. 30 by Anton Bueschen, MD, president of AUA. In it, Dr. Bueschen said, AUA "has serious concerns" about a number of the proposed provisions.

    The final rule is to be issued by Nov. 1 and implemented on or after Jan. 1, 2010.

    While CMS's proposed regulation includes a 21.5% reduction in Medicare payments for next year, Congress is expected to eliminate part, if not all, of that cut in the coming months, perhaps as part of the health care reform legislation now in discussion. However, there are numerous additional provisions that would affect urologists. AUA, through Dr. Bueschen, has commented extensively on these:

    • Physician-administered drugs: AUA welcomes CMS's proposal to remove physician-administered drugs from the data used to calculate physician payments under the current sustainable growth rate (SGR) formula. (The SGR may be revised as part of health care reform.) CMS has said that removing those drugs from the formula would not change the projected 2010 payment schedule, but it would reduce the number of years physicians would be subjected to cuts in the future.

    "We were happy to see, in the technical correction, that modest cuts and eventually, an increase in the payment update will result," AUA told CMS.

    • Practice expense relative value units (RVUs): CMS is proposing to update specialty-specific practice expense RVUs based on data from a new American Medical Association Physician Practice Information Survey, which AUA says would apparently result in a 7% reduction for urology.

    AUA has challenged the accuracy of the AMA data as it relates to urology practices, and had urged CMS to postpone using it in 2010 and to continue using AUA's supplemental survey information regarding urology practice costs until differences can be resolved.

    • Imaging equipment usage. AUA "strongly opposes" the CMS proposal to change the practice expense calculation portion of the Medicare formula, the assumption being that imaging equipment priced over $1 million is used 90% of the time, rather than the current 50%. Lower payments would result from that change. AUA disagrees with CMS's conclusion that the equipment is being used more frequently, noting that in many urology practices, particularly those in rural areas, imaging use rates are as low as 25%.

    CMS reasons that as the use of the equipment in-creases, per-treatment costs for purchasing, maintaining, and operating the equipment declines, making a reduction in payment appropriate.

    • Imaging accreditation requirements. CMS proposes to implement a requirement approved by Congress last year that technicians who operate advanced imaging equipment be accredited by Jan. 1, 2012. Mobile units, physicians' offices, and independent diagnostic testing facilities would be affected, but not the physician who interprets the test results.

    AUA has urged CMS to "recognize a broad array of accreditation organizations that will respect the needs of different specialties in performing imaging."

    • Ceasing recognition of consultation codes. AUA opposes CMS's proposal to stop paying for consultation codes, typically billed by specialists and paid at a higher rate than equivalent evaluation and management services.

    Under the new plan, practitioners would use existing E&M service codes when providing these services instead, with savings being redistributed to increase payments for existing E&M services. If adopted, AUA has said, the proposal would introduce different coding standards for Medicare and private payers and would undercut the goal of administrative simplification that was part of the Health Insurance Portability and Accountability Act of 1996.

    • Physician Quality Reporting Initiative (PQRI). The proposed rule contains a number of provisions to promote improvement in the quality of care and patient outcomes through revisions to the Electronic Prescribing Incentive Program and PQRI. Eligible professions or group practices that meet the requirements in 2010 will be eligible for incentive payments equal to 2% of their total estimated allowed charges.

    Urging Congress to continue incentives for PQRI beyond 2010, AUA has said CMS "should maintain flexibility and uniformity in reporting time frames for all PQRI reporting options." Further, "urologists have become very frustrated because they have not received any feedback from CMS on their PQRI submissions." AUA has urged CMS to provide feedback reports regarding whether physicians' submissions comply with the program and stating that quality information is being successfully reported.

    AUA also warns that CMS is underestimating the costs that physicians incur in submitting PQRI information.

    "CMS should recognize that electronic health record (EHR) systems are extremely expensive, with costs well beyond the CMS estimate of $1,500 to over $4,500 to purchase an EHR product," Dr. Bueschen said in the AUA letter.

    "For many physicians, the CMS 'conservative estimate' of a cost of $2,750 for an eligible professional to report PQRI data through electronic health records is too low, and should be revised to yield more realistic projections."

    Bob Gatty, a former congressional aide, covers news from Washingtonfor Urology Times.

    Bob Gatty
    Bob Gatty, a former congressional aide, covers news from Washington for Urology Times.

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