HBMA disagrees with CMS fee schedule from a billing perspective

Since the Centers for Medicare & Medicaid Services (CMS) issued a notice of proposed rulemaking (NPRM) with changes to the 2012 Medicare Physician Fee Schedule, organizations including the American College of Radiology, the Medical Group Management Association and the American Academy of Family Physicians have responded with criticism. Healthcare Billing & Management Association (HBMA) has joined the list of those organizations unhappy with the CMS' NPRM.

The Laguna Beach, Calif.-based HBMA sent a letter to CMS Aug. 26 that included comments from a billing perspective. “Although CMS’ NPRM did not specifically solicit comments about the operational aspects of SGR [Sustainable Growth Rate] transitions, our 2011 experiences, we believe, warrant the comments provided,” wrote Jackie Davis-Willett, CHBME, president of HBMA.

The letter stated that while there is little latitude in making legislatively mandated cuts in physician payments due to the SGR formula, the organizations urged CMS to prevent the projected 29.5 percent cut from occurring.

“Reducing the conversion factor…would have a devastating impact on physician income and, ultimately, access to care for Medicare beneficiaries,” Davis-Willett wrote. "In our communication with the thousands of physicians served by HBMA’s member companies, we have been told, almost universally, that such a cut would be a proverbial ‘show stopper,’ forcing practices to cease serving Medicare patients entirely, or drastically reducing their Medicare patient load – simply to survive.”

The organization recommended that CMS convene a workgroup of representatives from the provider, medical billing and compliance communities to develop an administratively reasonable, cost efficient and compliant mechanism for reprocessing under/over-paid claims, should there be events similar to those that occurred in the past and in 2010-2011.

Proposed changes to the Physician Quality Reporting System (PQRS) do not appear to offer any material participation efficiencies or improvements in the incentive payments. This suggests that practices that have elected to not participate will nontheless recognize improvements that will lead them to reconsider, according to HBMA.

HBMA recommended that CMS investigate how PQRS incentives might be made more financially relevant. “It is our observation and belief that unless or until the incentives are, truly, incentives – either way – meaningful participation will not occur,” the letter continued. Additional recommendations included registry options that should permit and support multiple pathways/formats and that the term “validation strategy” should be clarified and more fully defined.

“Once defined, CMS should solicit further formal (NPRM) or, at least, informal input, from interested parties before adopting final rules and/or policies,” Davis-Willett added.

“HBMA appreciates the opportunity to respond to this NPRM and remains interested and available to work with CMS should you seek to modify or further research the practicality of the proposed rules or new or substitute rules,” the letter concluded.

Read the 12-page letter here.