This Week – August 23, 2014

This Week in Washington DC:

  1. Take Action: Contact CMS re: Upper and Lower Endoscopy Valuation & Reimbursement

ACG and the GI societies met with CMS on Monday, August 18th to discuss the value of colonoscopy and methodologies used as part of this review process. The societies also continue to urge CMS to revise the methodologies used to arrive at interim final values for upper endoscopy codes, which were published last November and resulted in significant reimbursement cuts.

As you may recall from our previous alerts, ACG and the GI societies garnered the support of numerous members of Congress earlier this year on the need for greater transparency in the rulemaking process. Due to ACG and the GI societies’ advocacy efforts, CMS has proposed a new process to increase transparency in rate-setting that will begin in calendar year (CY) 2016. Despite this significant success, the proposed timeline will not benefit the lower endoscopy codes that are currently under review nor the upper endoscopy codes that are currently pending as interim final.

On Tuesday, August 19th, the Presidents of ACG, AGA and ASGE sent a letter to CMS Administrator Marilyn Tavenner formally requesting a 1 year delay in making reimbursement changes to the colonoscopy family of codes. ACG urges you to do the same.

We need your help to make sure that the voice of gastroenterologists throughout the country is heard. Send comments on the proposed fee schedule rule to CMS by September 2nd.

To comment:

  1. Visit the official Federal Government portal for submitting public comments on the proposed rule here.
  2. Copy and paste the template letter below into the box labeled "Comment."
  3. If interested, supplement the letter with any of your personal experiences that you want considered.
  4. Enter your individual contact information and press the blue "Continue" button at the bottom of the page.
  5. Review and submit.

Please stay tuned for further updates. Please also share and discuss your thoughts with fellow ACG members on the ACG GI Circle. To login and share your comments, go to and sign in as a member. Once you have done so, click here and then click the orange "Visit ACG GI Circle" button to be taken to the GI Circle site. If you have not yet activated your ACG GI Circle account, please email us at

Contact Brad Conway, VP Public Policy, with any questions or for more information.

Brad Conway


Dear Administrator Tavenner:

As a practicing gastroenterologist, thank you for proposing in the CY 2015 Medicare Physician Fee Schedule Proposed Rule a new, more transparent system that provides physician organizations and other stakeholders the opportunity to participate meaningfully in the Medicare fee setting process. I agree with CMS that a new policy involving advance publication of rates and increased opportunity for public comment is a much improved way of instituting Medicare payment policy.

I am extremely disappointed, however, that this process will be first implemented for CY2016. Consequently, services that are currently under review, including potentially life-saving colorectal cancer screenings, will not benefit from the more transparent process CMS proposes to adopt. It is especially disheartening to know that CMS is not proposing to allow these services to be considered under the more transparent process at a time when we continue to witness studies documenting the effectiveness of these procedures in colorectal cancer prevention.

Given the proposed timeline for instituting the new transparency policy, I request that procedures currently scheduled for review as potentially misvalued be delayed for one year until the new process is in place. This would include delaying new valuations for lower endoscopy, as well as finalizing the significant cuts that were sustained by the upper endoscopy codes.

Gastroenterologists across the country are concerned about declining reimbursement rates for vital services that provide necessary screening and treatment for critical diseases and cancers. Learning of potentially significant changes in reimbursement rates for Medicare services two months prior to their effective date leaves providers very little time to understand and plan for major changes to their practices.

I understand that major policy changes take time to implement. A delay in valuing the gastroenterology codes that CMS identified as potentially misvalued is the least disruptive and more equitable way of implementing the new transparency process.

I urge you to listen to physicians throughout the country and delay codes identified as potentially misvalued currently under review until CMS’ new transparency process takes effect.

I thank you for your consideration.


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