December 4th, 2009

The Final CMS Rule Is Flawed

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The Centers for Medicare and Medicaid Services (CMS) Final Rule on the cardiology fee schedule (download the entire 450-page document here) is an ill-conceived policy change that will drastically affect the practice of cardiology in the United States. Relying on limited, unrepresentative data from the Physician Practice Information survey (PPIS) done by the AMA, the CMS determined that the cost of delivering care in a cardiology practice (the practice expense) went down by 40% in the last three years. Those of you involved in managing practices know that costs haven’t dropped at all — in fact, they have typically risen by several percentage points each year. A 40% drop is totally out of touch with reality.

As you might imagine, these alleged drops in practice expense have affected the formula by which RVU reimbursement is calculated. This leads to very significant cuts in scheduled payments to cardiology practices, especially those with large imaging practices (particularly the 36% cut in nuclear imaging). In our own practice, the projected impact in 2010 will be a 12% reduction in Medicare revenue as well as reduced reimbursement by all payers with contracts tied to the resource-based relative value scale (RBRVS). (The ACC offers a Practice Impact Calculator to help you determine how these cuts will affect your practice.) These reductions will continue over the next four years, and that does not include the additional 21.2% cut in physician payments mandated under the sustainable growth rate (SGR) formula.

Our practice will need to make significant program and service cuts to preserve our viability. Many practices in the country will be similarly hurt. If imaging shifts to the hospitals, costs will rise significantly, because in 2010, planned Medicare reimbursement to hospitals for these studies is nearly triple the rates set for physician practices.

The ACC has provided excellent leadership on this issue, advocating in Washington for all cardiologists. Their efforts have stimulated a strong grass roots movement and may have been responsible for spreading the impact of these cuts over the next four years. Still, the ACC is unsatisfied with this result and is fighting hard for further reversals of this misguided CMS policy. Without question, this change will affect access and service for our patients needing quality cardiac care. I hope that you’ll agree with me and with the ACC about this rule. Whatever your thoughts, I strongly encourage you to do two things: write your representative in congress and share your thoughts below with the CardioExchange community.

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