I am incredibly frustrated and disappointed today. Devastating cuts to reimbursement for lifesaving colonoscopy exams under Medicare’s Physician Fee Schedule are proposed despite advocacy by ACG and its sister GI societies in the past few years.
I want the GI community in the United States to understand the fundamental lack of fairness which underlies the process that got us to this cut. The process is flawed. The outcome is flawed. Worst of all, we risk a reversal of the progress our nation is making to increase use of colorectal cancer screening by colonoscopy for Medicare beneficiaries, who by virtue of their age, are at higher risk for colorectal cancer.
A year ago, ACG and the GI societies help convince the Centers for Medicare/Medicaid Services (CMS) to postpone its determination of the value of colonoscopy reimbursement under Medicare. Today we face a cut to the diagnostic colonoscopy code (45378) work value RVU from 3.69 to 3.29 – an 11% cut, with cuts to the other codes in the colonoscopy family ranging up to 19%.
Are you doing 11% less work during your colonoscopies than in previous years? I didn’t think so.
The obscure process and behind–the- scenes maneuvering that produced these cuts is may be even more discouraging than the cuts themselves, and reflects a level of unfairness and disregard for evidence that is antithetical to sound health care policy. CMS’s plans to cut colonoscopy are contrary to its own policy goals of expanding colorectal cancer screening and prevention through its “80% by 2018” initiative supported by other agencies within HHS and CDC.
It is clear from the cut to 45378 and related lower GI codes announced July 8, 2015 that CMS ignored the data, CMS ignored the arguments from the GI societies, and CMS ignored fundamental fairness. The methodology CMS applied to the colonoscopy family of codes is both inappropriate and unrealistic.
Instead of relying on survey data and the real-world clinical experience of the GI community, CMS applied a flawed analysis based on fundamentally inaccurate recommendations from the AMA-convened Relative Value Update Committee, known as the “RUC.” The colonoscopy cuts do not reflect the reality of current endoscopy practice as underscored by data gathered jointly by the three GI societies and provided to the RUC and CMS. The agency demonstrates a total disregard for data from our member surveys which we developed with, and which were approved by, the RUC – a survey which was consistent with other previously accepted precedents when valuing Medicare reimbursement codes. This is egregious because these data were painstakingly collected, carefully analyzed, and presented along with recommendations based upon robust evidence as well as GI’s best thinking to inform the valuation of the physician work value and practice expense components of the Medicare physician fee for colonoscopy.
CMS completely disregarded this good faith effort by the GI community.
Compounding my frustration is a sense that CMS failed to look at the colonoscopy work value realistically or holistically. Instead, the agency relied upon flawed numbers from the RUC to build a flawed foundation for its valuation of the colonoscopy base code. During the RUC’s colonoscopy review under the Misvalued Codes Initiative and throughout the past year, ACG objected to the RUC’s procedures and failure to abide by their own rules and processes. Underlying the cuts to colonoscopy are actions by the RUC and assumptions in its analysis which are clearly wrong.
The reality is that colonoscopy is a high-volume procedure, which places it squarely in CMS’ cost containing cross-hairs. Cuts to colonoscopy were a pre-ordained outcome so CMS was apparently not going to let a small detail like the evidence from our survey stand in the way of their intention to slash colonoscopy reimbursement.
I recognize your frustration. I want to assure you that there have been coordinated and concerted efforts by all three GI societies on your behalf over the past few years with the overarching aim of protecting the progress we have made in reducing colorectal cancer mortality and expanding use of colonoscopy for colorectal prevention.
The GI societies have already scheduled a meeting with CMS officials later this month to voice our objections to these cuts.
YOU CAN TAKE ACTION
One constructive step you can take is to encourage your Members of Congress to enact the provisions of the SCREEN Act (S.1079/ H.R.2035). In preparation for these cuts, the ACG Governors were on Capitol Hill this spring urging Congress to pass the SCREEN Act, as this is the only legislation before Congress that addresses colonoscopy reimbursement and can help mitigate these proposed Medicare cuts.
Use this link to connect with your legislators and share your outrage and concern and urge them to co-sponsor the SCREEN Act. There is an opportunity to have your voice heard by commenting on the proposed cuts to CMS. The College will share the deadline and instructions on how to write to CMS in subsequent communications.
Stephen B. Hanauer, MD, FACG, ACG President
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