The AAMC Sept. 6 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS) Physician Fee Schedule (PFS) proposed rule for calendar year (CY) 2017, which updates payment rates and changes payment policies for 2017. The rule includes several proposed policy changes that would impact academic medical centers.
CMS proposes a burdensome and complex data collection process to revalue global surgical codes that would involve having all surgeons report on claims pre and post-operative care in 10 minute increments. The AAMC opposes reporting services in 10-minute time increments and asks that CMS require claims reporting only from a “representative sample” of surgeons, including teaching physicians and non-teaching physicians, and a variety of specialties, as the statute intended.
CMS also seeks feedback on how to track the services that residents provide during pre- and post- operative visits. The AAMC recommends that teaching surgeons use specific modifiers included in the teaching physician guidelines for billing when a resident is involved in the patient’s care. The guidelines require that a teaching physician must be present during all critical or key portions of a visit to bill the service.
In regards to the Open Payments system, the AAMC recommends that CMS facilitate the process to verify the accuracy of payments to teaching hospitals by including additional non-public text fields to assist in the review and affirmation or dispute of payment reports, as well as develop additional guidance on payment reporting and pre-vetting through input from key stakeholders.
The proposed rule also includes a slight reduction in the payment update for 2017 to fund additional payments for codes related to primary care, care coordination, behavioral health, and services for patients with mobility impairments. The AAMC supports the CMS proposal for add-on payments for primary care management/coordination and cognitive services; however, the association believes CMS must ensure that it accurately projects the utilization for these new codes to avoid making across the board reductions in payment under the fee schedule.
CMS proposes the Medicare Diabetes Prevention Program (MDPP) as a part of its efforts to improve population and preventive health efforts. While the AAMC is appreciative of the expansion of the MDPP, the association recommends CMS be less stringent with the payment structure to encourage maximum participation.
Finally, the AAMC’s comment letter also includes key recommendations regarding revisions to the Accountable Care Organization attribution methodology and quality measures, the Value-based Modifier program’s informal review process, and appropriate use criteria for advanced diagnostic imaging services.
The final rule is expected to be released in November 2016.