The Medicare Payment Advisory Commission (MedPAC) is an independent Congressional agency established to advise Congress on issues affecting the Medicare program. MedPAC released a report on June 14, 2013 which, as expected, proposed “leveling the playing field” between Medicare payments for the technical component of several services in physicians’ offices (paid according the Physician Fee Schedule [PFS]) and the amounts paid for similar services in hospital outpatient departments (OPDs). One of the options proposed by MedPAC—to “level the playing field” for select cardiovascular imaging services (echocardiography and nuclear cardiology)—is of particular concern to ASE.
MedPAC notes in its report that “reducing OPD payment rates for these groups of cardiac imaging services would reduce program spending and beneficiary cost sharing by $500 million in one year.” Based on 2013 TC and APC allowances, the reductions would range from 42% to 82%, with transthoracic echocardiogram with spectral and color Doppler (CPT 93306) reduced by 64%. This single CPT code, 93306, is critically important, as it represents approximately 87% of echocardiography billings to CMS.
The MedPAC report states that the differences in payment rates for the same services provided to similar patients treated in private practice and in hospital settings have resulted in physicians migrating from private practice to OPD settings. However, the report fails to mention that, while most physicians would have preferred to maintain their independent practice, a flawed survey conducted five years ago by CMS was the basis for draconian cuts to the PFS. Such cuts created an unsustainable environment for many physicians in private practice. Between 2009-2013, the PFS payment for code 93306 was cut by an average of 9% annually, forcing many physicians to merge their practices with hospitals.
MedPAC’s report also neglects to acknowledge that slashing OPD payment rates to the untenable rates paid for services performed in private physicians’ offices will greatly impact patient access to care. This policy will have a disproportionate impact on center-city, small, and rural hospitals. These facilities are more fragile financially and will not be able to operate as previously, resulting in even greater disparities in access to care.
MedPAC’s implication is that Congress can fund a Sustainable Growth Rate solution in part with the projected savings from equalizing OPD and physician’s office payments. Rather than proposing a resolution that distributes the financial burden evenly across medicine, however, cardiology—and more specifically echocardiography—will again bear the brunt of healthcare payment reductions.
ASE has taken three major steps to prevent these cuts proposed by MedPAC from becoming law. First, we have reached out to the American Hospital Association, which is actively lobbying to prevent the cuts to OPD payments, and both organizations are working on a coordinated campaign. We are also working on a response strategy with our colleagues at the American College of Cardiology and the American Society of Nuclear Cardiology. Second, ASE has also developed a 3-pronged alternative to these profound cuts that focuses on quality, appropriateness, and reducing medically unnecessary repeat studies. Third, ASE has retained an experienced lobbyist to work with our Congressional allies on this issue for the remainder of 2013.
ASE is committed to advocating for an environment of excellence in the quality and practice of cardiovascular ultrasound, and we are working hard to ensure that the voice of cardiovascular ultrasound is heard in Washington.
The importance of successful advocacy by ASE is emphasized in this unique issue of the Journal , which for the first time sees the publication of three major guideline documents:
Guidelines for Performing a Comprehensive Transesophageal Echocardiography Examination
Clinical Recommendations for Multimodality Cardiovascular Imaging of Patients with Pericardial Disease
Expert Consensus for Multi-Modality Imaging Evaluation of Cardiovascular Complications of Radiotherapy in Adults
These three ASE guidelines illustrate the remarkably important role of echocardiography in cardiac diagnosis and of JASE in physician education. ASE must fight to preserve patients’ access to care—and particularly to the wonderful clinical tool that is echocardiography.