Proposed 2011 Physician Payment Schedule
On August 24, 2010 the AMA submitted a comment letter to the Centers for Medicare and Medicaid Services’ (CMS) regarding the proposed physician fee schedule rule for CY 2011. The AMA’s principal recommendations are as follows:
• The AMA strongly supports the proposed comprehensive review of the Medicare Economic Index (MEI). The MEI needs to reflect the realities of medical practice in the 21st century and the AMA welcomes the proposed review. Until this review of the MEI is completed, CMS should withdraw the changes it has proposed to the MEI for CY 2011, as well as the revisions to the relative value units (RVUs) and geographic practice cost indexes (GPCIs) that arise from the proposed changes to the MEI.
• CMS should revise the Physician Quality Reporting Initiative (PQRI) feedback report proposal to ensure that this process improves successful participation in the PQRI program.
• To implement a successful informal PQRI appeals process, CMS should significantly improve the Quality Net Help Desk by adding more telephone lines and hiring more trained and experienced, qualified staff.
• The AMA applauds CMS’ decision to change the definition of group practice from 200 to 2, as it will allow more physician practices to participate in the group practice reporting option (GPRO) for 2011.
• CMS must publish detailed specifications for individual measures and measures groups for the PQRI November 15, 2010.
• The AMA applauds CMS’ decision to reduce the PQRI reporting sample requirement from 80 percent to 50 percent for FY 2011. The AMA urges CMS to also use its existing authority to apply the new 50 percent threshold retrospectively to the 2010 reporting year.
• The AMA supports enhancing the measures and methods used in the resource use Physician Resource Use Measurement and Reporting Program (RUR). Under this program, CMS must adequately prepare for handling additional feedback report requests and distribution techniques, and until adequate risk adjustment and attribution models are widely tested and applicable, these reports should not be publicly reportable.
• We strongly support CMS’ proposed requirements for the 2011 electronic prescribing (e-prescribing) incentive payment program, which is to require reporting on only 25 services involving electronic prescriptions.
• We strongly oppose CMS’ proposal to impose financial penalties in 2012 and 2013 against physicians based on their e-prescribing activity during the first six months of 2011. Instead, we strongly urge CMS to review 2012 and 2013 e-prescribing activity (not 2011 e-prescribing activity) in order to assess penalties in 2012 and 2013.
• We strongly recommend that CMS add more exception categories so that more physicians facing hardship will be eligible for an exemption from e-prescribing penalties in 2012 and 2013.
• We also recommend that CMS provide feedback reports to physicians and establish an appeals process to allow physicians to appeal decisions that affect their eligibility to take part in the e-prescribing program or that affect their ability to get e-prescribing incentives.
• CMS should take appropriate measures to ensure the accuracy of the list of successful e-prescribers and to provide the appropriate disclaimers for the website listing.
• The AMA strongly supports better coverage for preventive care. CMS should work through the established Current Procedural Terminology (CPT) Editorial Panel and the Relative Value System Update Committee (RUC) process to adopt existing CPT codes for the annual preventive visits rather than establishing separate Healthcare Common Procedure Coding System (HCPCS) G-Codes for these services.
• CMS should expand the availability of the primary care incentive payments by interpreting “allowed charges” as charges under the physician fee schedule, and not as all Part B charges.
• CMS should ensure that the general surgery bonus payments promote access to these important services for patients by modifying the Health Professional Shortage Area (HPSA) criteria to allow a non-HPSA hospital to be part of a HPSA if: (i) the hospital is adjacent to a HPSA; (ii) the patient resides in a HPSA; or (iii) the general surgeon maintains an office in a HPSA.
• CMS should seek input from the RUC and its Health Care Professionals Advisory Committee on the efficiencies or reduced resources involved in services provided to the same patient in the same session or on the same day rather than implementing arbitrary multiple procedural payment reductions for imaging and therapy services.
• The ACA contained a number of provisions that apply retroactively, which requires CMS to re-process claims for various physicians’ services. CMS should issue guidance to its contractors about reprocessing these claims in a manner that minimizes the burden on physicians and avoids further confusion and payment delays. CMS should also make this guidance publicly available so that physician organizations can disseminate it to our members.