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September 12, 2011

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HBMA Uses "Strong Language" in Comments to CMS about Physician Fee Schedule

The Healthcare Billing & Management Association (HBMA) released its comments about the CY 2012 Physician Fee Schedule Proposed Rule August 26.  In several of its comments HBMA didn't mince words in letting CMS know of its disapproval.

Below is a brief summary of HBMA's comments.  The complete 12 page document is available from PBN's website.

HBMA Fee Schedule Comments Summary

HBMA's comments cover five problem areas.  PBN covered two of them in previous issues of the Minute (follow the links to review previous articles).

1.  SGR Payment Solutions.  The HBMA again criticizes past lawmakers' playing kick the can with regard to physician pay and participant benefits under SGR.  They advocate developing a provider/biller/compliance community workgroup to help CMS develop a lasting solution to this nagging problem.

2.  PQRS/PQRI Programs and Registries.

Program Comments. HBMA's member surveys reveal some depressing news about the overall program . . .

• Very low physician participation levels,
• Bonus payment discrepancies or non-payment of bonuses without explanation, and
• discrepancies between physician-submitted data and the actual data used to calculate bonus payments.

These discrepancies " . . . left many in our industry skeptical of the integrity of the PQRI/PQRS program."

Registry Comments.   Companies who signed up to be "Registries" within the program, but also work with practices that have EMRs don't understand why CMS restricts billing entities to submitting claims through either EMR or through a Registry, but not both.

HBMA also described CMS' validation strategy requirements as so vague as to offer "no basis on which to evaluate the possible costs" or to evaluate whether the costs might make serving as a Registry "economically unfeasible."

HBMA Recommends that CMS:

A. Offer higher rewards for participation and stiffer penalties for non-compliance.  The current incentives and penalties are non-starters for motivating participation.

B. Be more flexible in the information pathways and formats allowed within the Registry program.

C. Clarify what's intended in regards to the "validation strategy" requirement, and gather input from "interested parties" to determine what is realistic and feasible for providers.

3. MPPR Expansion/Payment Reduction.  PBN summarized the Multiple Procedure Payment Reduction proposed policy and the discrepancies inherent to it earlier this summer.  HBMA states flatly, ". . . there is an extreme disconnect between CMS' policy proposal and actual medical practice."

HBMA also pointed out that CMS' estimate of a 50% cost savings from performing multiple diagnostic imaging procedures in the same "session" is not "supportable by any published data, analytics or statistics."  CMS's estimate is severely at odds with the few available efficiency studies.  For example, one study cites the potential for a 2.96% efficiency improvement for a CT procedure and 5.45% for an ultrasound procedure--about 10 times lower than CMS' estimates.

HBMA recommends that CMS withdraw the recommendation until the projected savings are supported by research and accurate industry-supplied cost data.  HBMA also recommends that CMS clarify definitions of the terms "encounter," "session," and other terms to better reflect actual practices.

4. Bundled Payments.  HBMA cited operational, logistical, privacy, and third-party billing company issues that would prevent implementation of CMS' proposed 3-day payment window policy for "Bundled Services."  HBMA also described the policy as potentially a "poison pill" for community-based healthcare providers.

HBMA recommends that CMS rescind the proposed rule until it is feasible for providers to comply.

5.  Payment for Annual Wellness Visits.   HBMA provides a detailed summary of how CMS has added significant new requirements (such as a Health Risk Assessment and other possible follow-on assessments) within the context of a single code for an annual wellness visit (AWV).   Existing codes allow for an average of 25 minutes for an AWV and 45 minutes for a Wellness/Preventive Visit-both of which are far under the actual average if the new requirements are to be met.

HBMA recommends that CMS suspend the new policy until it can be accurately quantified and then adjust payment accordingly.

What can I do about it?

Though the comment period ended August 31, it's not too late to let us know your opinions about the proposed rule and how it could impact your business.  Take our survey to let us know what you think.

To find out how PBN can help you guide your practice through the coming changes, contact . . .

PBN Business Development, 800.288.4901 or 

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Overland Park, KS 66210 | 800.288.4901 | pbnmed.com

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