The American Society for Gastrointestinal Endoscopy, the American Gastroenterological Association and the American College of Gastroenterology have issued comments and recommendations to CMS on the 2018 proposed rules for the Medicare Physician Fee Schedule, the Hospital Outpatient Prospective Payment System and the Ambulatory Surgical Center Payment System, which are expected to be finalized in early November.
In a joint letter to CMS, the societies commented on provisions of the PFS proposed rule that affect gastroenterology, including their support of new recommended values of anesthesia services for GI procedures, according to a press release from ASGE. CMS has proposed adopting the AMA Relative Value Scale Update Committee’s (RUC) recommended values for these anesthesia services, with each base unit valued at about $22.
The societies also expressed their support for proposed updates to the Evaluation and Management documentation guidelines “to reduce physician burden and to better align E/M documentation with the current practice of medicine.” They recommended these documentation requirements align with “the nature of the presenting problem, medical decision making and time with the patient,” and also praised the proposed reduction of documentation required for history of present illness and physical exam.
However, the societies recommended against the proposal to reduce the malpractice RVU for gastroenterologists, and instead “recommended that CMS maintain the CY 2017 risk factors used to determine the RVU, which include unique non-surgical and surgical risk factors.” In addition, they recommended CMS work with the GI societies to improve data collection for this provision.
Finally, the societies supported proposed changes to reporting criteria for the 2018 payment adjustment for the Physician Quality Reporting System (PQRS) and the Medicare Electronic Health Record (EHR) Incentive Payment Program.
“For both programs, CMS proposed to reduce the 2016 quality reporting criteria from nine to six measures,” according to the press release.
In a separate letter, the societies also issued comments regarding proposed changes to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System.
Regarding changes to ASC payment, the societies recommended that CMS “eliminate the growing disparity in the facility reimbursement rates between hospital outpatient departments (HOPDs) and ASCs,” highlighting that “the declining reimbursement for ASCs jeopardizes the ability to perform Medicare cases in this more cost-effective setting,” according to the press release. Additionally, they recommended that ASC payments be set at a fixed percentage of the OPPS rate.
The societies also advised CMS to include 16 additional GI services and infusion services in ASC-covered surgical procedures.
Further, they expressed support for proposed changes to the ASC Quality Reporting (ASQCR) Program, including a delay in the mandatory implementation of the Consumer Assessment of Healthcare Providers and Systems Outpatient and Ambulatory Surgery Survey (OAS CAHPS).
“As CMS seeks opportunities to repeal, replace, or otherwise modify burdensome regulations, our societies commented that CMS should finalize its proposal to make OAS CAHPS participation voluntary,” according to the press release.
The societies noted that they will provide updates to members after reviewing the final rules in November.
ASGE. GI Societies Comment on the 2018 Payment Rules. Accessed September 22, 2017. http://ow.ly/nhTE30fj2hC