The Heart Rhythm Society submitted comments regarding the 2010 Medicare Physician Fee Schedule proposed rule to the Centers for Medicare and Medicaid Services (CMS) by the August 31, 2009 deadline. Read the full comment letter (PDF, 700K), which addresses the following issues:

American Medical Association (AMA) Physician Practice Information Survey (PPIS)
The Heart Rhythm Society expressed serious concerns about the validity of the data, given that only 55 out of 145 respondents supplied information that was useable for practice expense per hour calculations. The Society also questions lack of transparency in the PPIS data.

The Society is requesting that CMS defers its action to use the PPIS data and instead continue to rely on the validated 2002 supplemental survey date for cardiology services until the survey process has undergone further evaluation.

Consultation Services
CMS is soliciting comments on its proposal to eliminate the use of all consultation codes in a budget neutral manner by increasing the work Relative Value Units (RVUs) for new and established office visits by approximately 6 percent to reflect the elimination of the office consultation codes. The Society believes that this proposal is impetuous and supports the AMA recommendation to allow time to determine whether the new “transfer of care” definition will address issues with the use of consultation codes.

Medicare Physician Payment SGR Formula
Physicians are facing a -21.5 percent cut across the board in their reimbursement rate starting January 2010, with cuts for the next several years estimated to a total of 40 percent. The Society urges CMS to work closely with Congress to avert the -21.5 percent cut and revamp the current flawed Sustainable Growth Rate (SGR) formula with a stable mechanism to update physician payment rates under the Medicare Fee Schedule.

Physician-Administered Drugs
The Society supports CMS’ proposal to use its administrative authority to remove the cost of physician-administered drugs from the SGR formula retroactive to the 1996/1997.

Equipment Use Rate
CMS is proposing to change the usage assumption from the current 50 percent usage rate to a 90 percent usage rate for equipment priced over $1 million. The Society opposes this proposal, and recommends that CMS work with physician organizations to conduct an accurate survey of equipment usage. If the new survey demonstrates that the current data are not accurate, a more accurate rate should be transitioned over a three-year period.

Value-Based Purchasing Program
The Society also offered recommendations for CMS’ consideration on its plan to transition to a Value-Based Purchasing program for physicians and other practitioners.

Physician Quality Reporting Initiative (PQRI)
On August 27, 2009, the Heart Rhythm Society submitted a separate comment letter to the CMS regarding the PQRI program addressing four topics: value of registries, timeline for transitioning from claims-based reporting, scope of quality reporting for EPs and the deficiencies in the PQRI program.