This Week – September 7, 2011

This Week in Washington DC:

  • ACG submits comments to CMS Proposed Rule on 2012 Medicare Physician Fee Schedule and Related Policy Changes
  • ACG submits comment to CMS Proposed Rule on 2012 Medicare HOPD and ASC Reimbursement and Related Policy Changes

ACG Urges CMS to Incorporate Quality Measures Pertinent to GI
ACG and ASGE on August 30 urged the Centers of Medicare and Medicaid Services (CMS) to incorporate more relevant quality measures into the Physician Quality Reporting System (PQRS).  In 2012, providers successfully reporting PQRS measures via claims, a qualified registry, or through a qualified electronic health record (EHR) are eligible to receive an additional bonus of .5% of all Medicare Part B fee for service charges.  However, beginning 2015 Medicare providers will face a 1.5% reimbursement cut for not successfully participating in PQRS and a 2% cut in 2016 and beyond.  CMS proposes to use the CY 2013 PQRS reporting period for the 2015 payment adjustment. 

ACG and ASGE requested that CMS include those quality measures pertinent to the GI clinician before the PQRS becomes punitive.  These measures include: “comprehensive colonoscopy documentation” and “endoscopy and polyp surveillance: appropriate follow-up interval for average risk patients.”  Together with the two colorectal cancer screening related measures in PQRS, CMS has the ability to develop a “colorectal cancer screening” measures group that will not only help ensure greater participation in PQRS but also are pertinent to GI clinician, are outcome-based, and will improve the continuum of care for colorectal cancer screening. This continuum of care includes:  identifying those Medicare beneficiaries who have yet to be screened; the quality of the screening itself; and the necessary follow-up patient care.  These measures will also align the quality improvement efforts for both CMS and the GI Quality Improvement Consortium (GIQuIC) so that providers would qualify for PQRS by participating in GIQuIC.

The societies also urged CMS to provide clear and useful guidance when developing PQRS measure specifications for the newly included inflammatory bowel disease (IBD) measures later this year. 

Please click here to view the ACG-ASGE comment letter on the 2012 Medicare Physician Fee Schedule Proposed Rule.

In a separate letter, ACG also joined the AGA and ASGE in submitting comments to other proposed policy changes contained in the proposed rule. 

Specifically, the three GI societies urged CMS to:

  • Revise the agency’s proposed process in reviewing and auditing physician services that CMS has reason to believe are “misvalued.” 
  • Slow its projected timeline when implementing the “value-based physician payment modifier” as CMS intends to use the confidential physician feedback reports as the means to distribute comparable cost and quality data to physicians.  However, many problems with the physician feedback reports have been documented and the Government Accountability Office (GAO) has also criticized CMS’s ability to disseminate these reports to the physician community. 

Please click here to read the tri-society letter to CMS on the 2012 Medicare Physician Fee Schedule Proposed Rule.

ACG will continue to monitor these policies and reimbursement changes impacting clinical GI and will continue to represent the interests of the GI clinician when working with CMS.

ACG Urges CMS to Revise Proposed ASC Policy Changes Beginning 2012
ACG also joined the AGA and ASGE in submitting comments to the 2012 proposed rule on hospital outpatient department (HOPD) and ambulatory surgical center (ASC) payments and other policy changes. 

CMS is proposing to implement ASC quality reporting requirements beginning 2012, based on eight quality measures in order for an ASC to be eligible for a full update in 2014.  However some of these quality measures are not relevant to the GI ASC such as: Prophylactic IV Antibiotic Timing; Ambulatory Patient with Appropriate Method of Surgical Hair Removal; Prophylactic Antibiotic Selection for Surgical Patients – first or second generation Cephalosporin; and Surgical Site Infection Rate. 

The societies request CMS to revise this newly created “ASC Quality Reporting Program” to require endoscopy centers to report only those measures that are relevant to their ASC, especially as CMS intends to move forward with the plan to tie ASC quality reporting to facility reimbursement in 2014.     

Beginning 2013, and to be eligible for a full ASC update in 2015, CMS also proposes ASCs report two additional “structural measures”: use of a safe surgery checklist; and volume data for certain high-volume ASC surgical procedures (all patients).  This list includes many codes related to gastroenterology such as colorectal cancer screening and codes 40000-49999, among others.

The societies urged CMS for more consistency as current CMS ‘conditions of coverage’ guidelines already require an ASC participating in the Medicare program to have certain policies and procedures in place that serve as a “safe surgery checklist.”  Also, the societies question what quality improvement data is derived from CMS’s proposal to collect ASC patient volume data for colorectal cancer screening codes without other specific colorectal cancer screening measures in place (see above: ACG and ASGE comments regarding PRQS).

The comment letter also includes recommendations to align the ASC inflationary update as well as any future ASC “productivity adjustment” to that of the HOPD instead of using the consumer price index (CPI-U) to measure the increase in costs for ASCs but the Medicare Economic Index for the HOPD setting.  Currently, CMS ties ASC reimbursement to the HOPD but uses different indices to measure ASC costs and inflation.  This must be revised for both consistency and fairness.  ASC reimbursements continue to decrease when compared to the HOPD setting and CMS’s use of different indices exacerbates this problem when measuring the same type of input costs for each outpatient setting. 

Please click here to read the tri-society comment letter on the 2012 ASC/HOPD Proposed Rule.

ACG will continue to monitor proposed policy changes and be a strong advocate for GI endoscopy centers and other physician-owned facilities.                

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, visit  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