The Centers for Medicare & Medicaid Services (CMS) proposed rules for the Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (HOPPS) contained a mixed bag for echocardiography, with both good and concerning recommendations.
In the PFS, CMS addressed transthoracic echocardiography (TTE) and stress codes. Since ASE has a RUC advisor status, last year the society directly participated in the Medicare reimbursement code change review and valuation processes. ASE worked on the RUC review of primary transthoracic echocardiography CPT code 93306, as well as CPT codes 93307 and 93308, and stress echocardiography codes 93350 and 93351. As a result of the 2015 PFS proposed rule, CMS identified two TTE codes (93306 and 93351) as “Potentially Misvalued Codes” as determined through a “High Expenditure Specialty Screen.” ASE dedicated significant resources to urging our U.S. physician members to respond to the RUC requested surveys, which provided the basis for AMA’s RUC valuation of medical services. The robust survey results were critically important in developing a strong ASE presentation to the RUC. ASE’s presentation to the RUC was well received, resulting in RUC recommendations to increase the wRVUs for 93306 from 1.30 to 1.50, and to maintain the current values for stress echocardiography. The proposed PFS rule indicates that CMS accepts these recommendations.
CMS is also recommending additional payment rate changes for non-exempted off-campus provider-based hospital departments paid under Medicare. The current statute requires that certain items and services furnished by off-campus hospital outpatient provider-based departments no longer be paid under the HOPPS beginning January 1, 2017. For Calendar Year (CY) 2017, CMS finalized the PFS as the applicable payment system for most of these items and services. CMS is now proposing to reduce current PFS payment rates for these items and services by 50 percent.
This year CMS is again proposing significant restructuring of Ambulatory Payment Classifications (APCs) for imaging services, consolidating several APCs. This proposal results in significant reductions to Medicare payment for contrast-enhanced transthoracic echocardiography. This action is part of a broader initiative by CMS to consolidate and restructure the Ambulatory Payment Classifications (APCs) for imaging services.
Working with a number of organizations, ASE has identified a well-thought-out alternative APC grouping methodology which would preserve adequate reimbursement for contrast-enhanced echocardiography. Geoffrey Rose, MD, FASE, an ASE Advocacy Committee member and ASE Board member, Denise Garris, the society’s CMS/RUC/CPT consultant, and Irene Butler, ASE’s Vice President of Health Policy, were joined by representatives from both ACC and SCMR in Baltimore to meet with key decision makers from CMS to address the inadequate proposed payment rate for contrast-enhanced echocardiography. ASE focused our presentation to CMS on demonstrating that contrast echocardiography improves patient outcomes and can reduce overall costs while highlighting the benefits of the society’s alternative APC grouping methodology.
While the final rule is not expected until November, the meeting was positive and collegial, and we are proud that we were able to present a united voice in opposing this cut while also providing a viable alternative. ASE has submitted formal written comments to CMS on both the HOPPS and Physician Fee Schedule (PFS) proposed rules.
ASE continues to work to develop strong relationships with private payers as well. Recently ASE signed an agreement with the Blue Cross Blue Shield Association to work with them on their Evidence Street™ initiative.
Evidence Street™ was created to make BCBSA’s evidence review process of medical technologies and therapies more transparent, efficient, and comprehensive. BCBSA collects and analyzes available peer-reviewed evidence on devices, diagnostics and pharmaceuticals, then synthesizes that data, and determines if the evidence is sufficient or insufficient to determine the effect on health outcomes.
ASE continues to work to demonstrate that echocardiography improves patient care and ensure that this modality is properly reimbursed.