2009-07-17

The Centers for Medicare & Medicaid Services (CMS) released its proposed Medicare Physician Fee Schedule for 2010. Once again, physicians are facing a significant reduction in Medicare payment unless Congress acts. CMS projects a negative update of -21.5 percent for the 2010 Medicare Physician Fee Schedule due to the application of the sustainable growth rate (SGR) formula. This will result in a CY2010 conversion factor (CF) of $28.3208. This represents a decrease from the 2009 CF of $36.0666. Negative updates have been expected every year since 2002, although Congressional action has averted payment reductions since 2003. Congressional action will be needed again in order to avoid a payment reduction in 2010.

ASH has developed a detailed analysis of the key issues and potential impact on hematology. Specific areas that ASH members should be aware of include:

• Overall impact on hematology: Of particular concern to ASH members is that hematology/oncology is estimated to experience an impact of minus 6 percent from the various payment policy changes in the 2010 proposed rule.
  
  • - 5 percent from the new data from the Physician Practice Information Survey (PPIS). The PPIS sought to quantify common professional expenses associated with medical practice
  • -1 percent from new professional liability premium data and other technical changes to the calculation of professional liability costs
• Changes to SGR: CMS is proposing to remove physician administered drugs from the calculation of allowed and actual expenditures. While this proposal would not change the update for 2010 it would reduce the past discrepancy between actual and targeted expenditures and would reduce the number of years in which physicians are projected to experience a negative update.
• Elimination of consultation codes: CMS is also proposing to stop making payment for consultation codes. Practitioners would have to report existing Evaluation and Management (E/M) service codes when providing these services instead. While the details of this proposal are still emerging, it has the potential to negatively impact specialists who predominately report consultation services.These services are paid at a higher rate than E/M services. Resulting savings would be redistributed to increase payments for the existing E/M services.
• Changes proposed to physician quality programs: Although the proposed rule expands opportunities for participation in the Physician Quality Reporting Initiative (PQRI) and the Electronic Prescribing Incentive Program (e-Prescribing Program), CMS also noted that they are considering limiting the claim-based mechanism of reporting to PQRI after 2010 and are proposing that there should be a minimum patient sample size for at least one measure to enhance the scientific validity of the performance results. ASH has been an active participant in the development of the programs and has appreciated the efforts of CMS to improve them and encourage physician participation. However, the Society believes as the program moves forward it should continue to be designed in a manner that allows the greatest number of physicians to participate. ASH is cautiously reviewing the implications of the proposed changes and the impact that they could have on hematologists.
• CMS seeks comments on the creation of a group of experts to provide input on the valuing of physician work: Recently the Medicare Payment Advisory Commission (MedPAC) recommended the establishment of a group of panel of experts separate from the AMA RVS Update Committee (RUC) to review and recommend values to CMS on physician work. CMS is seeking public input on this idea and the best way to implement and integrate a new entity into existing processes.

ASH will be providing comments to CMS by the August 31 deadline. If you have any specific concerns or questions, please contact ASH Senior Manager, Policy & Practice, Carol Schwartz at 202-776-0544.

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