This Week – February 8, 2014
- GI Societies to Meet CMS Officials on Reimbursement Cuts to Upper GI Endoscopy Codes
- Agreement Announced on SGR Reform
- ACG Working with the U.S. Preventive Services Task Force on Updating Colorectal Cancer Screening Recommendations
ACG and GI societies to discuss significant cuts to upper GI reimbursement
On Jan. 27th, the GI societies submitted joint comment letters for the 2014 Medicare Physician Fee Schedule (PFS) and the 2014 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System Final Rules. We provided an in-depth, code by code analysis of why we believe the methodologies used to determine the 2014 Medicare Physician Fee Schedule reimbursement rates for certain upper GI endoscopy codes were flawed and unwarranted. In addition, for the OPPS/ASC letter, we provided comment on the ambulatory payment classification assignment for GI codes and the new endoscopy surveillance measures in the ASC quality reporting program.
The GI societies are committed to fighting these reimbursement cuts on your behalf. As such, we are scheduled to meet with CMS officials soon to discuss our review of CMS’ decisions, as outlined in the tri-society comment letters.
How significant are these reimbursement cuts? How do the changes in RVUs impact your practice?
The GI societies have compiled 2014 Medicare reimbursement charts for popular GI procedures and services paid under the PFS, ASC and OPPS. The charts reflect the current rates as of February 2014. They are subject to change due to the three-month moratorium of the Sustainable Growth Rate (SGR) formula cuts (ending March 31st) and a 2 percent cut due to sequestration (effective April 1st).
Please know that our societies continue to explore all options to mitigate these cuts to endoscopy services.
ACG members should also know that potential cuts to colonoscopy may be on the horizon. This is one reason why ACG continues to urge Congress to pass the SCREEN Act (S. 608 / H.R. 1320) despite the divisive political environment on Capitol Hill. This bill improves quality of care in our specialty, lowers patient barriers to life-saving colorectal cancer screening, and also strives to ensure Medicare reimbursement for colonoscopy is fair. This is a very crucial time for clinical gastroenterology and our patients. Please urge your leaders to support the SCREEN Act:
ACG will continue to fight Medicare reimbursement cuts that threaten clinical GI and the patients we serve.
Medicare reimbursement reform package clears another hurdle on Capitol Hill
On Thursday, February 6th, the congressional committees of jurisdiction on Medicare provider reimbursement announced an agreement on repealing the SGR formula and reforming Medicare physician reimbursement. This effectively clears another hurdle as SGR reform continues to move through Congress. The Senate Finance, the House Ways & Means, and the House Energy & Commerce Committees released a brief outline describing this agreement. Please click here to read the one-page outline of the agreement.
It is important to note that while they agreed to the substantive policy changes, there was no discussion on “offsets” or how to pay for the bill. These discussions will likely make or break any chance of the bill getting pushed through each chamber for final passage. Congress must act before March 31st in order to prevent the 2014 SGR formula cuts (effective April 1st). Even if there is no consensus of the larger SGR reform package, ACG expects Congress to pass another short-term moratorium of the looming SGR cuts.
The Senate Finance Committee and House Ways & Means Committee passed their versions of SGR reform in December 2013, while the Energy & Commerce Committee passed its version in July 2013.
The agreement on Thursday would give providers a 0.5 percent annual update for 2014 through 2018, and then maintain the 2018 rates through 2023. Starting in 2018, providers’ payments would be adjusted based on a new “Merit-Based Incentive Payment System” (MIPS), which combines and modifies current quality performance incentive programs such as the physician quality reporting system or PQRS and the value-based payment modifier. Providers would receive a score from 0 to 100 based on their performance in four categories: quality, resource use, meaningful use of electronic health records and clinical practice improvement activities. Providers would also get credit for improving from one year to the next in the quality and resource use categories. Payments would be based on where the provider’s performance score falls in a performance threshold. Providers with composite scores above the threshold would get positive payment updates, and those with scores below would get negative adjustments.
Professional societies such as ACG would help determine which quality measures should be used in the MIPS performance periods. ACG worked with the committees throughout 2013 to get this provision in the package as well as language allowing the use of clinical registries to help meet quality reporting requirements.
In 2024 and after, providers in approved alternative payment models (APMs) would get annual updates of 1 percent, and all other providers would get annual updates of 0.5 percent. Providers that participate in eligible APMs would be exempt from the MIPS. These providers would receive a 5 percent bonus if they receive a significant portion of their revenue from an APM or a “patient-centered medical home.” Providers would have to receive at least 25 percent of their Medicare revenue through an APM in 2018 and 2019, and that percentage would increase over time.
ACG will continue to advocate for clinical GI as this SGR package moves through Congress.
USPSTF updating colorectal cancer screening recommendations
On Wednesday, February 5th, ACG submitted comments to the U.S. Preventive Services Task Force’s (USPSTF) solicitation for input on updating colorectal cancer screening recommendations. The USPSTF last updated these recommendations in 2008. The revised recommendations are expected sometime in 2015.
ACG and the 2008 multi-society task force on colorectal cancer screening both maintain that colorectal cancer prevention should be the primary goal of screening. Also, that screening modalities should be grouped into colorectal cancer prevention tests vs. colorectal cancer detection tests. In its 2009 colorectal cancer screening guidelines, the ACG also stipulates that since colorectal cancer prevention is the primary goal, complete optical colonoscopy is the preferred screening modality as all other screenings and tests (including flexible sigmoidoscopy) require a follow-up optical colonoscopy subsequent to any positive finding.
ACG’s letter also states:
“While many describe optical colonoscopy as the “gold standard” in CRC screening, any discussion regarding a “gold standard” in colorectal cancer screening must not be misinterpreted as a “silver bullet” in preventing and eradicating colorectal cancer. The best test is the test that gets done.”
The USPSTF recommendations have a significant impact on Medicare, Medicaid, and other private insurance coverage determinations. Thus, ACG also urged the USPSTF to clearly stipulate when updating its recommendations that polypectomy is considered part of a “screening,” as this is the intended purpose of certain recommended screenings such as flexible sigmoidoscopy and optical colonoscopy. Pursuant to the Affordable Care Act, this USPSTF stipulation may allow CMS to waive patient cost-sharing for those screenings turning into therapeutic procedures. ACG is also fighting to resolve this Medicare coverage quirk on Capitol Hill as well, via the SCREEN Act and other legislation introduced in the House of Representatives.
The ACG also urged the USPSTF to updates it recommendations to stipulate that African Americans should be screened beginning at age 45.
Please click here to read ACG’s letter to the U.S. Preventive Services Task Force.
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 gi.org 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 email@example.com.
Contact Brad Conway, VP Public Policy, with any questions or for more information.