A recent CMS proposal may be a positive step for those of us in academic institutions or private practices whose “value” is benchmarked off the relative value unit (RVU) system but spend a significant amount of our time performing lower RVU evaluation and management (E&M) services to complex patients.
As part of the proposed 2016 Medicare Physician Fee Schedule , CMS is seeking stakeholder feedback on creating codes for cognitive services that require more time and work than traditional E&M services. The goal of such efforts would be to better describe and value the physician work (time and intensity) for these complex patients.
The creation of new codes for cognitive services has the potential for more accurate reimbursement from Medicare but also for institutions to better recognize our “value” as clinicians when providing quality care to these patients.
For example, the growing complexity of diagnosis and management of IBD patients is an area of medicine where gastroenterologists must grapple with extraordinary complicating disease features of fistula, abscess, obstruction, postoperative sequelae, biologic therapies and changing paradigms of therapy. Diagnosing and managing the care of IBD patients is further confounded by the inherent challenges of the increasing elderly patient populations’ co-morbidities, polypharmacy, cognitive and social care, which are not adequately reflected by the RVU system.
Additionally, the current RVU system, does not adequately take into account the time required to review all prior data and communicating with past physicians, radiologist, or surgeons.
All of these efforts are essential to ensuring a correct diagnosis and subsequent management. This is vital to intelligent care but many GI clinicians performing cognitive services believe the required work and resources are virtually ignored by the present E&M valuations. The incredible time commitment required for discussion with each patient and family members is equally ignored.
We urge ACG members to let CMS know that you support this proposal. Please follow the step-by-step instructions below to let CMS that these codes are necessary for GI:
Follow These Steps to Comment:
- Visit the official federal government portal for submitting public comments on the proposed rule. Click here.
- Copy and paste this template letter into the box labeled “Comment Now.” (blue box in upper right-hand corner of the screen) (template letter attached)
- If interested, revise this letter with any of personal experiences that you deem helpful.
- Enter your individual contact information and press the blue “continue” button at the bottom of the page.
- Review and click “submit.”
Seymour Katz, MD, MACG
Clinical Professor of Medicine- New York University School of Medicine – NYC, New York