Society Comments on 2011 MPFS

On August 24, 2010, the Heart Rhythm Society submitted comments on the 2011 Medicare Physician Fee Schedule proposed rule (MPFS) to the Centers for Medicare and Medicaid Services (CMS). Read the full comment letter (PDF, 500K), which focused on those aspects of the proposed rule that are of interest to Society members.

Consultation Services
The Society reiterated its initial concerns, and the concerns expressed by the broader medical community, with CMS' decision and the potential consequences of the policy change. In the comments letter, the Society reported on the survey results released July 16, 2010 by the American Medical Association (AMA). Approximately 5,500 physicians completed the survey, results of which revealed that many practices have taken a number of cost-cutting steps to offset revenue losses associated with elimination of the consultation codes. (In April, the Heart Rhythm Society partnered with the AMA and 16 other medical specialty societies to develop a survey to understand and quantify how CMS’ policy is affecting physicians.)

The Heart Rhythm Society remains strongly opposed to CMS' decision to discontinue consultation codes and urges the agency to reverse its current policy and resume payment for these services under the Medicare program.

Remote Cardiac Monitoring Services
We concurred with CMS' proposal to correct the direct practice expense (PE) inputs for Holter and event monitoring device services (93224, 93225, 93226, 93230, 93231, 93232, 93268, 93270 and 93271) so that the inputs for the global only codes reflect the appropriate summing of the PE inputs for the associated PC only and TC only codes. CMS also proposed to correct the database monitor equipment time for Holter codes 93225, 93226 and 93224.

The Heart Rhythm Society appreciates the manner in which CMS is attempting to update its database and supports the agency in making certain the equipment time inputs for Holter monitor services are accurate. CMS noted its ongoing concern regarding development of practice expense RVUs for remote monitoring equipment that is utilized 24 hours a day, 7 days a week in a centralized location. Given the significance of this matter, the Society expressed an interest in working with CMS and other external stakeholders to address the fundamental issues affecting valuation of equipment use for these services.

Rebasing and Revising of the Medicare Economic Index
CMS is proposing to rebase and revise the Medicare Economic Index (MEI) and incorporate it into the CY 2011 Physician Fee Schedule update by removing all costs related to drug expenses, and expenses associated with separately billable supplies.

While the Society appreciates the effort CMS has devoted to make certain that the adjustment will reflect appropriate economic index data to measure cost for providing physician services, the Society urges CMS to defer implementation of the proposed revision until the technical advisory panel has been convened and allowed to review all aspects of the MEI.

Potentially Misvalued Services Under the MPFS
One of the provisions from the health care reform law mandates the Secretary of the Department of Health and Human Services to periodically review and identify potentially misvalued services and make the appropriate adjustment. The provision allows CMS to use the existing mechanisms established by the AMA/Specialty Society Relative Value Scale Update Committee (RUC) or to create new ones.

The Society continues to support the RUC process, as it allows for physician input from a variety of disciplines on relative value recommendations to CMS for new and revised codes.

The proposed rule also implements several quality related provisions from the health care reform law, and make a number of significant changes in the Physician Quality Reporting Initiative (PQRI). The Society submitted a second set of comments to CMS on those quality related changes.