On September 6, ASA submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on a number of issues included in the Proposed Rule for the 2014 Medicare Physician Fee Schedule. Specific issues addressed in the communication included:
ASA supports CMS' proposal to revise the Medicare Economic Index (MEI). This issue is important to anesthesiologists since it is the reason for the forecasted positive 3 percent impact the rule would have on anesthesiology's allowed charges.
ASA is in sharp opposition to CMS' proposed changes to the Physician Quality Reporting System (PQRS), expressing strong disagreement with CMS' proposal to increase the minimum number of measures that eligible professionals (EPs) must report from three to nine. ASA argued that the minimum number of required measures should not exceed the maximum number applicable to any EP. ASA also vigorously asserted that CMS must maintain the claims-based reporting mechanism until all specialties and EPs are able to successfully report via a registry or other means.
ASA urged CMS to apply a more effective strategy to ensure that physician anesthesiologists are reporting on the quality of patient care received and not just the quantity of services provided. This request urged CMS:
- Acceptance of the four measures submitted for inclusion in PQRS 2015;
- Incorporation of anesthesiology CPT codes into existing measures; and
- Consideration of the role anesthesiologists play in a team-based surgical/procedural setting.
The Society's comments also addressed CMS' proposals for the 2016 Value Based Payment Modifier (VBPM). ASA expressed disagreement with the proposal that the 2016 VBPM be applied to groups of 10 or more EPs; we recommend setting that threshold at 50 EPs. Recommendations were also provided regarding CMS's establishment of cost metrics, patient attribution methods and benchmarking structures for the 2016 VBPM.
Review ASA's comments to CMS on the Proposed Rule for the 2014 Medicare Physician Fee Schedule.
Review the Proposed Rule for the 2014 Medicare Physician Fee Schedule.
Learn more about the PQRS.
Learn more about the VBPM.