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ASA submitted formal comments on the proposed 2016 Medicare Physician Fee Schedule, which outlines proposed changes to policies and payment rates for services rendered on and after January 1, 2016. In its comment letter to the Centers for Medicare and Medicaid Services (CMS), ASA addressed potentially misvalued services, the Physician Quality Reporting System (PQRS) and the Value Based Modifier, as well as implementation of the new Medicare Access and CHIP Reauthorization Act (MACRA), the law creating the new physician payment system.
In the proposed rule, CMS suggests the addition of anesthesia code 00740— Anesthesia for upper gastrointestinal endoscopic procedures, endoscope introduced proximal to duodenum— and code 00810— Anesthesia for lower intestinal endoscopic procedures, endoscope introduced distal to duodenum to the misvalued code list because of the “significant change in the relative frequency with which anesthesia codes are reported with colonoscopy services.” ASA explained that increased utilization of anesthesia with these procedures is not indicative of misvalued services, and recommended these codes be removed as misvalued codes. CMS has recognized the importance of screening colonoscopy and anesthesia services associated with such screening. In this case, it is not any valuation anomalies that drive increased utilization, but CMS’s own recognition (with which ASA heartily agrees) that these services are of such importance that patients are encouraged to undergo the procedures through the use of appropriate payment policies. ASA’s comments emphasized the importance of undergoing colorectal screening and the increased likelihood of patients receiving screening if they receive safe and effective anesthesia care. Further, the costs of anesthesia along with the colonoscopy are far outweighed by the overall benefits to both patient and population health; CMS should consider not only dollars spent, but also dollars saved.
Additionally, ASA recommended that the following CPT Codes not be identified as misvalued, arguing that the codes are currently properly valued:
• 31500- Intubation, endotracheal, emergency procedure,
• 36556- Insertion of non-tunneled centrally inserted central venous catheter; age 5 years or older
• 36620- Arterial catheterization or cannulation for sampling, monitoring or transfusion (separate procedure); percutaneous
• 93503- Insertion and placement of flow directed catheter (e.g., Swan-Ganz) for monitoring purposes
As part of the MACRA implementation, ASA urged CMS to take steps to ease the transition for physician anesthesiologists into the new payment system. ASA is eager to work with CMS to ensure opportunities for cross-specialty collaboration are available in the Merit-based Incentive Payment System (MIPS) framework, the new system that will score physicians based upon their adherence to 4 separate assessment categories. Physician anesthesiologists are frequently collaborating in the care of a patient with other physicians, an important consideration in approaching the development of systems to measure patient outcomes, resource utilization, quality improvement efforts and other features of the MIPS framework. In regards to required clinical practice improvement activities (CPIA) as defined in MACRA, ASA suggested that for physician anesthesiologists, this could mean participating in one or more of the clinical data registries within the Anesthesia Quality Institute. For example, this might include the National Anesthesia Clinical Outcomes Registry (NACOR), Anesthesia Incident Reporting System (AIRS) and MOCA® Practice Performance Assessment and Improvement (PPAI). In its letter, ASA proposed that CMS allow the CPIA framework under MIPS to recognize not only individual activities, but also those activities that involve multiple providers. Including these activities will be powerful opportunities for producing improvements in quality and efficiency.
Lastly, ASA recommended that CMS allow the reporting of five anesthesia care measures via the claims-based reporting mechanism, as many physician anesthesiologists primarily use this method. ASA looks forward to continuing to work with CMS to ensure members are able to report a sufficient number of measures that are meaningful to physician anesthesiologists, pain medicine physicians, critical care physicians, patients, CMS and the broader health care community.
Read the full letter ASA submitted on the Medicare Physician Fee Schedule proposed rule.
