CMS Rule Overview

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CMS Rule Overview
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Proposed Medicare Payment Cuts Threaten
Cardiology Practices

• CMS proposed using data from a new AMA Physician
  Practice Information Survey (PPIS) to calculate
  practice expense RVUs
• Impact of proposal devastating for all
  cardiology, but especially for office-based
  practice
• Our goals
• Stop implementation in 2010
• Work w/physician community for a better solution

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Practice Expense RVUs Background

• Resource based PE RVUs implemented beginning
  1999
• CMS uses 19 step formula to calculate the PE RVUs
  for each CPT code
• Specialty specific PE per hour used in the
  formula
• AMAs Socioeconomic Monitoring Survey (SMS) from
  1995 1999 currently the source of most PE per
  hour data

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Supplemental Practice Expense Surveys

• Cardiology and other specialties believed SMS
  information was not accurate
• Congress required CMS to set up process to review
  supplemental data submitted by specialties
• CMS criteria conducted independently, nationally
  representative, met precision standards
• Cardiology supplemental data used for PE RVUs
  since 2007

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AMA PPIS

• Specialties that did not provide supplemental
  data wanted new, multi-specialty survey
• Pressure on CMS to find current PE per hour for
  all specialties
• AMA agreed to conduct multi-specialty survey,
  asked specialties to contribute
• Survey took almost 2 years and 2 contractors to
  complete

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Cardiology and PPIS

• ACC along with other specialties contributed
  funds to AMA for PPIS, encouraged members to
  participate
• Cardiology response was low only 55 provided
  complete PE information
• PE per hour much lower than results from
  supplemental survey
• ACC analysis doubtful that 55 responses are
  representative of cardiology

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CMS and PPIS

• CMS agreed to purchase data from AMA
• CMS did not obtain an independent analysis of the
  PPIS data like that required for supplemental
  surveys
• Information provided to public to support CMS
  proposal is inadequate for evaluating the quality
  of the survey process and data
• CMS doesnt believe careful analysis is needed

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ACC Position

• Dont use PPIS data for 2010 RVUs
• Conduct a thorough analysis of PPIS and provide
  analysis for public review
• Open a dialogue with the physician community
  about best way to move forward

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Next Steps

• Public comment period now closed. Final Rule to
  be published by November 1.
• CMS can withdraw this proposal, but probably will
  not without political pressure.
• Thank House members who signed Gonzales/Rogers
  letter.
• Ask others to write to or call CMS, HHS Secretary

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Final Points

• CMS proposal is independent of health reform
  bills and any SGR fix.
• Your members of Congress can help regardless of
  position on health reform.
• Final Rule for fee schedule will include other
  cuts for cardiology, so taking PPIS off the table
  is critical.