The Heart Rhythm Society continues its efforts to prevent cuts in Practice Expense relative values for heart rhythm services in calendar year 2010. On July 28, 2009 the Society and other medical associations met with several high-ranking Centers for Medicare and Medicaid Services (CMS) officials to discuss its decision to use data from the American Medical Association (AMA) Physician Practice Information (PPIS) survey to calculate practice expense RVUs for cardiology services in 2010. The data, if implemented, will result in practice expense cuts as high as 35 percent for some electrophysiology services provided to Medicare patients.
Joining the Society in expressing concern were the American College of Cardiology, the Society for Cardiovascular Angiography and Interventions, the American Society of Nuclear Cardiology, and the Society of Cardiovascular Computed Tomography. During the meeting, these cardiovascular specialty societies expressed a lack of confidence in the PPIS survey and requested that CMS pull back on its decision to implement the data for the 2010 fee schedule until an external review and validation has been completed.
CMS was questioned on the lack of transparency, as well as the validity of the PPIS data, given that only 55 out of 145 respondents supplied information that was useable for practice expense per hour calculations. Collectively, the societies represent more than 56,000 cardiology professionals. It was emphasized that a one-third response rate is far too low to be an accurate reflection of the financial and operational costs associated with cardiology practices.
CMS was also questioned on whether or not the same precision requirements mandated for the supplemental surveys were applied to the PPIS data, as it is not evident in the National Proposed Rule Making that the PPIS data were held to the same strict criteria established for supplemental practice expense surveys. This raises further concerns about the validity of the data.
CMS officials were limited in their responses, but remained confident in the belief that the PPIS survey data is the most comprehensive source of practice expense survey information available to date. This is especially the case considering that the AMA’s Socioeconomic Monitoring System (SMS) survey data is nearly a decade old, and were never collected for the purpose of developing relative values.
The Heart Rhythm Society will further address our concerns in writing as part of our comments on the proposed rule (due by August 31, 2009). In addition, a legislative alert will be e-mailed in the next two weeks asking for member comments as we finalize our comments on the proposed rule.
