GI has been feeling the squeeze on Medicare reimbursement for several years, and it just got somewhat tighter.
by R. Bruce Cameron, MD, FACG
ACG’s Advisor to the AMA RVS Update Committee (RUC)
On July 7th, a proposed rule from CMS for the Medicare 2017 Physician Fee Schedule decouples moderate sedation from the payment for more than 100 GI endoscopic procedures. This move effectively reduces the physician work value by .10 RVUs and lowers your overall reimbursement (if you are not administering anesthesia yourself) – creating further downward pressure on your bottom line.
Up until now, CMS has never placed a value on moderate sedation work. The genesis of the proposed rule is a 2014 announcement by CMS that the Agency would look to separate moderate sedation services from procedural codes in all specialties where the underlying procedure is performed with moderate sedation.
Reimbursement for GI endoscopic procedures will be reduced if the endoscopist doesn’t administer moderate sedation.
Under the proposed rule announced July 7th, there will be no financial impact for gastroenterologists who perform their own moderate sedation. You will just report two codes instead of one beginning January 2017 — the procedure code and the new moderate sedation code.
However, gastroenterologists who use anesthesia professionals will see the value of the majority of GI endoscopy procedures reduced by 0.10 RVUs.
GI has already sustained drastic cuts over the past four years.
ACG recognizes your frustration and appreciates the real world implications you have provided for your practice and your patients. We have shared your anger that GI procedures have been targeted by CMS for slashed reimbursement over the years, simply because of their high volume and to meet Medicare cost control mandates from CMS and Congress.
This latest move by CMS to create separate codes for moderate sedation means further erosion in Medicare payments for endoscopic procedures. GI procedures fared better than other specialties whose procedures face a .25 RVU valuation for moderate sedation. It’s noteworthy that CMS listened to the GI societies as opposed to the AMA RVS Update Committee’s (RUC) recommendations, which were higher. Nonetheless, it is perhaps a small consolation that things could have been worse, when overall, the rule would cut reimbursement for GI endoscopic procedures between 2 and 3 percent if you don’t administer your own moderate sedation.
CMS Considered Data from ACG, AGA, and ASGE
In March, as ACG’s physician representative to the RUC, I joined with AGA and ASGE to meet with regulators at CMS. We made a case to the Agency about the appropriate value of moderate sedation. The data we presented were based on the survey responses provided by members of the three GI societies.
In the proposed rule, CMS acknowledged the work of the GI societies as follows:
“We also note that stakeholders presented information to CMS regarding specialty group survey data for physician work. The stakeholders shared survey results for physician work involved in furnishing moderate sedation that demonstrated a significant bimodal distribution between procedural services furnished by gastroenterologists (GI) and procedural services furnished by other specialties….”
“…To account for the separate billing of moderate sedation services, we are proposing to maintain current values for the procedure codes less the work RVUs associated with the most frequently reported corresponding moderate sedation code so that practitioners furnishing the moderate sedation services previously considered to be inherent in the procedure will have no change in overall work RVUs. Since we are proposing 0.10 work RVUs for moderate sedation for the GI endoscopy procedures, this means we are proposing a corresponding .10 reduction in work RVUs for these procedures. For all other Appendix G procedures that currently include moderate sedation as an inherent part of the procedure, we are proposing to remove 0.25 work RVUs from the current values.”
The next step in the regulatory process is a public comment period on the proposed rule. This could change when CMS releases the final rule this November. While we are pleased that CMS rejected the RUC’s even more draconian cuts at our urging, you can be assured that as the College moves forward with our comments to CMS and in our advocacy with the Agency, ACG is committed to work tirelessly on your behalf to represent the best interests of clinical GI practitioners.
R. Bruce Cameron, MD, FACG
ACG Representative to the AMA’s RVS Update Committee (RUC)