Last year ASE worked on the RUC review of primary echocardiography CPT code 93306, (and the rest of the transthoracic echo family of codes) as a result of the 2015 MPFS proposed rule. CMS identified two TTE codes (93306 and 93351) as “Potentially Misvalued Codes” as determined through a High Expenditure Specialty Screen.
ASE sought to involve all our members in response to the RUC request for survey responses. This robust response helped us support these codes, and potentiated a well-received presentation by ASE to the RUC.
We are pleased that CMS has accepted the RUC recommendation to increase the wRVUs for CPT code 93306 from 1.30 to 1.50 wRVUs. Additionally, CMS will maintain the current wRVU values for the remaining transthoracic and stress echocardiography services. I would like to thank all of you who took time out of your busy schedules to complete the RUC surveys and provide ASE with the data needed to achieve this outcome.
Again this year, the Centers for Medicare and Medicaid Services (CMS) proposed cuts to echocardiography with contrast performed in the hospital outpatient department setting.. This would have directly negatively impacted the use of contrast echocardiography since the proposed payment rate was inadequate to cover the resources required for contrast and its administration.
ASE worked with several organizations and our IRT partners to develop an alternative proposed APC grouping methodology, which CMS ultimately accepted, and which preserves adequate reimbursement for contrast-enhanced echocardiography.
This month the American Medical Association (AMA) held its interim House of Delegates meeting. There were several resolutions that may be of interest to you:
- ASE was a co-sponsor of Resolution 234 that encourages AMA to work with CMS to ensure sound methodologies for risk adjustment for physicians with patient populations at risk for high resource use; and directs the AMA to lobby the Congress and the federal government to expedite development of an equitable, validated patient-specific risk adjustment mechanism and not include a cost score in the Merit Based Incentive Payment System (MIPS) until such time as it can be developed. This resolution was recommended for referral for decision.
- Resolution 210, Merit-Based Incentive Payment System and Small Practices, asks the AMA to advocate for a policy that exempts self-employed small practices, defined as solo practitioners of up to five physician providers, from the burdensome regulation of the Merit-based Incentive Payment System (MIPS). The HOD reaffirmed this resolution.
- Resolution 214, Advanced Practice Registered Nurse Compact, was adopted. The resolution calls for the AMA to convene an in-person meeting of relevant stakeholders to initiate a national strategy to address the APRN (Advanced Practice Registered Nurses) Compact. One significant concern is that an advanced practice nurse may be able to obtain certification of licensure in a more liberal state that allows independent activity and then because of the compact, also obtain licensure in all other states that have signed on to the compact.
- The HOD also adopted CSAPH Report 4, National Drug Shortages Updates. The report is a comprehensive strategy for addressing drug shortages.
- Resolution 808, Opposition to Reduced Payment for the 25 Modifier, was adopted and requires the AMA to include in its model managed care contract, provisions that will require managed care plans to adhere to CPT rules concerning modifiers and, in the case where a procedure is appropriately modified by a modifier 25, require that both the procedure and evaluation and management are paid at 100% of the non-reduced, allowable payment rate.
- At this meeting there again was a resolution addressing the site of service differential. The resolution call for appropriate facility fees for both hospital owned facilities and independently owned non-hospital facilities, computed using the real costs of a facility based on its fair market value; and provides independent practices with the same opportunity to receive reimbursement for uncompensated care as is provided to hospital owned practices.
I ask that you help ASE maintain a seat in the AMA House of Delegates. The milestones ASE has achieved would not be possible without a seat at this table. Please join the AMA by February 2018 to ensure cardiovascular ultrasound is appropriately represented, and that your interests, and your patients’ interests, are safeguarded.
In this challenging healthcare environment ASE is committed to work on your behalf and maintain a strong voice on legislative and regulatory issues!