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GI Societies Submit Joint Comments on the 2012 MPFS and HOPPS/ASC Proposed Rules

On August 30, ASGE, the American College of Gastroenterology (ACG) and the American Gastroenterological Association(AGA) submitted  joint letters to the Centers for Medicare and Medicaid Services (CMS) on the 2012 Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (HOPPS)/Ambulatory Surgical Center (ASC) Payment System proposed rules.

Medicare Physician Fee Schedule Proposed Rule

The joint comment letter on the MPFS addressed a number of provisions in the proposed rule that impact practicing gastroenterologists and the Medicare beneficiaries they treat. The overall impact of the proposed changes on gastroenterology-allowed charges is 0 percent, which could vary by practice depending upon mix of services and geographic locality. The societies provided comment on several payment policies relating to valuation of GI services. 

The societies also commented on proposals related to ongoing CMS quality improvement initiatives, including the Physician Quality Reporting System, the Electronic Prescribing Program, the Electronic Health Record Incentive Program, and the Physician Feedback Program. The letter also commented on CMS’ initial proposals related to the implementation of a value-based payment modifier for physicians, as required by the Affordable Care Act (ACA). 

Additionally, ASGE and ACG submitted joint comments on the quality measures that CMS proposes for inclusion in PQRS for the 2012 reporting period. The letter encourages CMS to improve the relevancy of PQRS measures to the services provided by gastroenterologists. The letter applauds CMS for inclusion of the Inflammatory Bowel Disease measures for 2012 and requests the inclusion of the additional endoscopy and polyp surveillance measures for 2013 PQRS.

The letter requests that CMS work closely with the specialty societies as it begins to develop a core measure set for gastroenterology.

HOPPS/ASC Proposed Rule

The tri-society letter on the HOPPS/ASC proposed rule continues to address the disparity in payment between HOPD and ASC.  The societies request that CMS make a prospective payment adjustment to ASC payment rates due to a significant CPI-U forecast error for CY 2011 and urges CMS to update ASC payments using the hospital market basket, to align ASC productivity adjustment with the HOPD and eliminate the secondary rescaling process applied in the ASC payment system.

The joint letter also addresses the specifics of the proposed ASC Quality Reporting Program. Under current law, CMS has the authority to impose a 2 percent reduction to ASCs that do not submit quality measures. CMS is proposing that the reporting period for the 2014 payment adjustment be Jan. 1, 2012-Dec. 31, 2012. The letter comments on the proposed quality measures for CY 2014, 2015 and 2016 payment determinations and the importance of an appeals process. The societies recommend a reporting start date of Oct. 2, 2012 and a reduced payment penalty of 0.4 percent reduction for CY2014, which is consistent with the initial inpatient hospital reporting program.

The final rules on the CY2012 MPFS and HOPPS/ASC Payment System should be released in early November. Summaries on many of the provisions in the proposed rules can be found on the ASGE website on the Government and Advocacy web page.