Weekly Roundup – July 24-28, 2023
Physician payment, coding, coverage, and quality reporting news highlights.
CAN’T LET IT GO – THE GREAT “Dr.” DEBATE
In the spirit of NPR’s politics podcast with its Can’t Let it Go feature, this week, I can’t stop thinking about a STAT News article that suggests we should get rid of the honorific title of “Dr.” in the medical setting. The authors argue that dropping the use of the term Dr. would be less confusing for patients and support collaboration among multi-disciplinary healthcare teams. If the article is not enough for you, the issue was further discussed on a STAT News podcast. I imagine most of you have strong opinions on this topic. I would love to hear from you. Please complete this anonymous, quick poll and let me know if you think the honorific of “Dr.” should be dropped. Results will be released next week. Now for the weekly update!
PAYMENT/FUNDING
Surgical Groups Urge CMS Not to Finalize Complex Patient Add-on Code (G2211) for CY 2024
On July 26, 2023, a coalition of surgical medical specialty societies submitted a letter to the Centers for Medicare and Medicaid Services (CMS) opposing the implementation of code G2211, an add-on code to office and outpatient visit codes (99202-99215) that describes patient complexity. CMS originally proposed the code for 2021, but Congress delayed its implementation until 2024.
The 2024 Proposed Physician Conversion Factor is: $32.7476. This is a reduction of 3.34% from the 2023 Physician CF of $33.8872. The change in value is driven by a 0% annual update, a negative 2.17% impact from budget neutrality adjustments, the expiration of the 2.5% statutory payment increase for CY 2023, and a 1.25% statutory payment increase for 2024. The agency estimates that G2211 accounts for 90% of the 2.17% work budget neutrality adjustment, negatively impacting the proposed 2024 physician conversion factor.
The societies note that with the recently updated coding structure for office/outpatient visits, clinicians can bill higher-level service codes for more complex patients, and the add-on code is unnecessary. They argue that code G2211 would cause disruptions to the fee schedule due to its impact on budget neutrality and that while other services in the resource-based relative value system that is the basis for the fee schedule have clear definitions of resource use, there is a lack of clarity in the definition of work and resources used for code G2211. In contrast, the internal medicine community has generally supported the implementation of code G2211.
Prices for Physician Services Increase Less than Other Medical Services and Consumer Goods, KFF Analysis Finds
A report published by the Kaiser Family Foundation found that medical service prices increased at a slower rate this past year than those for other consumer goods, which increased by 3%. Looking more closely at medical prices across services, there was a clear variation in growth. Prices for physician service grew at 0.5%, but it was dwarfed by inflation growth for hospital (4.2%), nursing care (3.3%), and prescription drugs (3.1%) prices.
The challenge for medical practices is that they purchase goods (e.g., rent, supplies, equipment) and services (e.g., staff wages and benefits) whose prices are impacted by higher inflation rates than the inflation rates for the services they provide to their patients for which they are reimbursed.
ARPA-H Releases First Funding Announcement: PSI to Improve Cancer Surgery Outcomes
The Precision Surgical Intervention (PSI) program was established by the Advanced Research Projects Agency for Health (ARPA-H). A challenge of oncological surgeries is determining where a tumor ends and where healthy tissues begin. This funding intends to support the development of technologies for tumor edge visualization and critical anatomy visualization. The call for proposals focuses on cancer surgeries and surgeries for any relevant conditions. A day for proposers is scheduled for September 7, 2023. Registration is on the ARPA-H website.
Established in 2022 and housed in the National Institutes of Health, ARPA-H’s mission is to invest in the development of breakthrough technologies to transform areas of health and medicine. The Biden Administration notes that this funding not only launches ARPA-H but also advances Biden’s Cancer Moonshot agenda.
PAYMENT INNOVATION
AMA, AHIP, NAACOS Partner on Value-based Care: Release Report on Data Best Practices
The American Medical Association (AMA), AHIP, and the National Association of ACOs (NAACOS) joined forces to develop best practices for value-based (VB) care. The initial effort of this new partnership is the release of, The Future of Sustainable Payment: Voluntary Best Practices to Advance Data Sharing.
In announcing this collaboration and releasing this document, the organizations noted that during the COVID-19 pandemic, practices under capitated care fared better financially. Since the pandemic, the market has been moving towards a more significant number of these arrangements.
While central to VB care is the collection, analysis, and implementation of lessons learned from data, practices participating in these arrangements have found that the need for standards and procedures for data sharing creates significant challenges. The groups note that the issues are too complex and variable to create a single solution, so the guidance provides best practices to help inform practices. This report outlines best practices for data sharing in the following areas:
Create an Interoperable Data Ecosystem: Adopt consistent content and exchange standards to simplify and expand data sharing.
Share More Complete, Comprehensive Data: Empower value-based care participants with complete, accurate, and consistent data that paints a more comprehensive picture of a patient or population.
Improve Data Collection and Use to Advance Health Equity: Collect and share data to identify and address health disparities as well as barriers to care beyond the clinical setting while ensuring transparency, appropriate use, and confidentiality.
Share Timely, Relevant, and Actionable Data: Prioritize sharing focused insights and data early, often, and in accessible ways, to improve care.
Share Data Methodologies, Calculations, and Context: Share detailed information on how and what data were derived from to foster trust among VBC participants in the data they receive, use, and by which performance is measured.
The groups are planning on releasing additional guidance in the near future. The next issue addressed is anticipated to be on payment methodologies.
CODING
2024 ICD-10-CM Update
On July 26, 2023, CMS released a document correcting errors in previously released documentation. The modifications are for fiscal year (FY) 2024, effective October 1, 2023, and relate to:
Code E35 Disorders of endocrine glands in diseases classified elsewhere
Code H35 Other retinal disorder
Main term Cachexia
ICD-10-CM (International Classification of Diseases, Tenth Revision, Clinical Modification) is used on all medical claims to report diagnosis codes that describe disease, illness, or injury.
2023 CPT Update
The most recent errata and technical corrections for the CPT 2023 code set were posted on June 30. These corrections are related to Molecular Pathology Gene Table and the Medicine Ophthalmoscopy subsection.
OPPORTUNITY TO ENGAGE
CMS Electronic Prescribing for Controlled Substances (EPCS) User Group
The agency is seeking prescribers or prescriber staff from rural and urban areas and varied specialties. The nine-member group will participate in usability testing and provide feedback to CMS to improve the EPCS Program. The deadline to apply for the CMS EPCS User Group is August 30th. A virtual kickoff meeting will be scheduled in September.
Section 2003 of the SUPPORT Act (Public Law 115-271) mandates electronic prescribing of Schedule II, III, IV, and V controlled substances under Medicare Part D and Medicare Advantage prescription drug (MA-PD) plans. The Merit-based Incentive Payment System also includes electronic prescribing measures.
OTHER UPDATES, IN BRIEF
Calls for Federal Oversight
A report released this week by the National Academies of Science, Engineering, and Medicine on addressing health disparities called for creating a permanent and sustainable entity within the federal government to improve racial, ethnic, and tribal equity across the federal government.
United States Senators Elizabeth Warren (D-Mass.) and Lindsey Graham (R-S.C.) released legislation that called for establishing a new commission to regulate online platforms.
Prior Authorization
The American Medical Association, American Hospital Association, AHIP, and the Blue Cross Blue Shield Association submitted a letter to CMS urging them not to finalize two rules with separate prior authorization (PA) standards. The organizations are concerned that this would result in multiple standards and workflows that could be costly and burdensome.
Regulations
CMS released the following regulations this week:
Requirements Related to the Mental Health Parity and Addiction Equity Act: Proposed Rule
FY 2024 Inpatient Psychiatric Facilities Prospective Payment System - Rate Update
For more information and questions, please contact:
Sheila Madhani, MA, MPH
Madhani Healthcare Consulting, LLC
Email: smadhani@madhani-health.com
www.madhani-health.com
Tel: (202) 679-2977