Society Responds to CMS’ Proposed Changes

Physician Fee Schedule for 2009

On August 29, 2008, the Heart Rhythm Society submitted comments to the Centers of Medicare and Medicaid Services (CMS) in response to the proposed rule Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2009; and Revisions to the Amendment of the E-Prescribing Exemption for Computer Generated Facsimile Transmissions as published in the Federal Register on July 7, 2008.

The Society’s comments urged CMS to restore payment cuts to holter monitoring services and commended the agency on its effort to ensure accurate practice expense values for cardiac event monitoring services. The comments also focused on potentially misvalued services, and recommended appropriate use of PQRI information, as well as presentation of the new features and capabilities of the next version of the ICD Registry.

In addition, the Society offered its perspective on a specific provision of the Medicare Improvements for Patients and Providers Act of 2008. Comments on the Anti-Markup provisions, the IDTF proposal, and exceptions to the Stark Law for Shared Savings Programs were submitted in a joint comment letter with the American College of Cardiology (ACC) and other cardiovascular stakeholders. View the Heart Rhythm Society’s letter regarding this payment policies rule (PDF, 408K)

Hospital Outpatient Prospective Payment System for 2009

On September 3, 2009, the Society submitted a second comment letter to CMS regarding its proposed rule Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2009 Payment Rates; Proposed Changes to the Ambulatory Surgical Center Payment System and CY 2009 Payment Rates ,which was published in the Federal Register on July 9, 2008.

The Society’s comments expressed concern about the projected rate reductions for device-dependent Ambulatory Payment Classifications (APC) for lead placement and cardiac resynchronization therapy (CRT) device implants, reiterated our opposition to payment packaging for intracardiac echocardiography (ICE), and requested that CMS not consider iatrogenic pneumothorax as a potential Healthcare-Associated Condition. View the Heart Rhythm Society’s letter regarding this OPPS rule (PDF, 264K)

CMS expects to issue both final rules on or around November 1, 2008.