The Centers for Medicare and Medicaid Services (CMS) on Nov. 1 released the final rule for the 2012 Medicare Physician Fee Schedule, which covers all payment rates for 2012 as well as many associated policies that govern the Medicare program. The rule is estimated by CMS to have an overall -2 percent impact on payments to cardiologists, however, individual impacts will differ substantially based on the mix of services provided by a practice. Highlights of the rule include:
Coding Changes
Under the final rule, physicians will no longer report separate codes when removing and replacing pulse generators on pacemakers and implantable cardioverter defibrillators (ICDs), and will instead report a single code for the combined service. The result of these coding changes and subsequent valuation efforts is an approximately 29 percent drop from current rates of payment.
For changes related to diagnostic cardiac catheterization, in 2011 a new set of 20 Current Procedural Terminology (CPT) codes for bundled diagnostic cardiac catheterization were created and given interim values by CMS. The 2011 interim values represented about a 10 percent cut compared to the combined values of the previous code set. CMS did not implement further reductions in values for diagnostic cardiac catheterizations despite consideration in last year’s final rule. The 2012 ACCF/AMA CPT Reference Guide for Cardiovascular Coding is now available.
CMS indicates that they intend to continue to review work and practice expense values for services that are potentially misvalued. In the rule, CMS indicates that it will review services that are high volume in a particular specialty. For cardiology, this means that the codes for 12-lead electrocardiogram (EKG) and stress tests will be reviewed for potential misevaluation in the coming year. However, this does not mean that the payment rate for the service rate will necessarily change. View a chart of the top CV codes.
Practice Expenses
The rule also requires that all services that include ultrasound equipment, including echocardiography, be reviewed to ensure that the payments reflect consistent practice expense inputs. This may or may not change the payment for services that include echocardiography equipment in 2013.
Imaging Services
CMS also expands the payment reduction for multiple imaging studies by 25 percent to include the professional component of these imaging services. The rule suggests that future rulemakings may expand this policy to other services. Common cardiology imaging services such as echocardiography, SPECT, and vascular ultrasound are not included on the list of codes that will be reduced.
Hospital-Owned Physician Practices
Under the rule, hospital-owned physician practices will not be paid separately for the technical component of any service provided in the three days prior to an admission to that hospital. For services that do not have a technical/professional split, the practice would be paid the facility rate which is lower than the non-facility rate. This is proposed to be expanded to include all services, including office visits, but will not be required until July 1, 2012.
E-Prescribing
Physicians and other eligible practitioners who did not report electronic prescribing (e-prescribing) in the first half of 2011 or who did not successfully file a hardship exemption by Nov. 8 will receive payments that are 1 percent lower than allowed by the physician fee schedule 2012. Practitioners have two options for receiving a 1 percent bonus and avoiding the 2013 e-prescribing penalty: e-prescribe at least 25 times at the time of service for one of the denominator codes during 2011, or e-prescribe at least 10 times in conjunction with any Medicare service from Jan. 1 through June 30, 2012.
Physician Reporting/Value-Based Purchasing
In 2012, successful participants in the Physician Quality Reporting System (PQRS) will receive a 0.5 percent bonus, a reduction of 0.5 percent in 2011. CMS continues to allow physicians multiple participation options, including claims-based submission, registry submission, and electronic health record (EHR) submission. There are also special methods for physicians in practices with more than 25 physicians. New for 2012, physicians who wish to participate in the program must report on quality for a full year. Physicians are still allowed to report on measures groups, allowing reporting on 30 patients to qualify for a full year. There are measures groups available for coronary artery disease and congestive heart failure as well as vascular disease.
The final rule lays the groundwork for a new program CMS is required to launch in 2015 that will adjust payments to physicians based on quality of care and resources used. CMS has also announced the measures that will be used to assess quality as part of the value-based purchasing initiative. Physicians will be assessed on the basis of core measures from the EHR incentive program as well as the PQRS program. CMS covers fewer details on the issue of resource use, but indicates that it is exploring multiple attribution methodologies in order to assign patient resource use to the appropriate physicians. Because of the lead time required to implement the value adjustment, CMS proposes that it will adjust payment on the basis of data from 2013 for the 2015 adjustment.
The ACC will continue to work with CMS throughout the year to ensure that decisions made by the agency continue to allow access to high quality cardiovascular care.