C.M.Mess (CMS) has
dropped a bomb on us in the 2010 payment rule. As background, over the past
decade, Medicare reimbursements for cardiology have been essentially flat while
practice business costs increased 2 - 3 percent a year, resulting in a “real
dollar” decrease in reimbursement and purchasing power by as much as 50 percent
since the mid 1990s.
As we approach health care reform, there has been optimism
among cardiologists and the ACC that improved viability of CV practices could come
about through incentives to improve quality, cut waste, and help society reduce
the overall rising costs of health care. Just at the moment when we have the
opportunity to focus on these quality incentives — which by the way are not yet
really included in the reform proposals other than in “rhetoric” — CMS comes
out with its 2010 Physician Fee Schedule Rule. OMG.
An 11 Percent Cut
We were expecting the worst,
but come on. The Centers for Medicare and Medicaid Services (See A Mess) projects that the proposed physician fee schedule changes would reduce total Medicare payments to
cardiology by 11 percent. The projected payment cut would result from changes
to the following areas: practice expense calculation; equipment utilization
rates; malpractice rate calculation; and payment for consultations. In
addition, CMS proposes a 21.5 percent reduction in the Medicare conversion
factor due to the flawed SGRrrr.
In short, there could be as
high as a 30 percent cut in Medicare payments for cardiology. Taken
together with the payment cuts cardiology has already experienced, CMS’
proposed rule represents a grave threat to cardiology practices and the
patients they serve.
Root Cause of the Cuts
How did this come about? Of
the 11 percent overall cut, more than 90 percent of it — a 10 percent cut
overall on average — results from an AMA survey of practice expenses that CMS
uses to estimate infrastructure costs of providing care. ACC hammered members
this year to volunteer to participate in the survey. Out of thousands of
practices asked to participate, only a few dozen did. It is a hassle, requiring
hours of tedious responses.
Unfortunately, the survey showed that cardiology
practices have experienced a 30 percent reduction in practice costs when most
other specialties showed increases! This is, of course, ridiculous, and we can
contest it. Right now, we don’t think this data has any
credibility since it only came from 55 respondents and was not subject to any
precision test by CMS to see if it is right.
Making these kinds of changes based on data that has not been validated
is indefensible. We paid for a survey in
2002 that had the same design and we had 3 times the number of respondents and
now that data has been thrown out for a survey that has never been
reviewed.
While we paid for the data, the AMA has not yet shared the complete
results and we’ll continue to work with AMA to see all of the data. Meanwhile, some of the other cuts, as in
echo, nuclear and other imaging services, while affected by this practice
expense issue, received a double whammy through cuts stemming from the RUC and
RVU adjustments.
What about ACCESS, CMS?
The focus on these flawed
formulaic cuts completely ignores the very important issues of access that are
certain to be created by huge slashes in payment. Services that have improved
countless lives by diagnosing and treating cardiovascular disease are scheduled
to have payment cuts in the range of 25 to 42 percent.
The ACC and our partners
are prepared to wage an aggressive campaign to prevent implementation of these
damaging policies. We have to turn this absurdity around. Incidentally, isn’t
great timing for Medicare -- a public
option -- to be demonstrating the arbitrary ineptness of the current public
options (Medicare and Medicaid) while the system reform debates about adding a
new public option are going on?
Take Action!
It is time to roll! The ACC implores
members to contact their lawmakers and ask them to prevent these unfair and
devastating payment policies that will produce serious CV access problems. Reach
your members using the ACC’s toll-free grassroots hotline (800-210-7193) or at www.acc.org/can. Detailed
information is available on the ACC Web site,
and more information will be out soon. For questions, contact advocacydiv@acc.org. President
Bove and the ACC officers and
staff are all over this crisis on your behalf!
All said, my final reflection on the bottom line of these
proposed cuts is that once again the profession has to focus on flawed federal
formulas and threatened cuts, rather than
on constructing payment reform and incentives to improve quality of care and
system efficiency! Bad timing. In
fact, horrendous timing.