Letter originally transmitted via e-mail
September 14, 2007
Kerry Weems, Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard,
Baltimore, MD 21244-1850
Re: [CMS-1392-P]
Dear Administrator Weems:
The Heart Rhythm Society welcomes the opportunity to provide written comments on the notice of proposed rulemaking CMS-1392-P entitled “Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2008 Payment Rates; Proposed Changes to the Ambulatory Surgical Center Payment System and CY 2008 Payment Rates,” published in the Federal Register on August 2, 2007. Our comments focus on the proposal to implement a composite APC for evaluation and ablation procedures, and to package certain intra-operative codes for payment in calendar year (CY) 2008.
HRS is the international leader in science, education, and advocacy for cardiac arrhythmia professionals and patients, and the primary information resource on heart rhythm disorders. Founded in 1979, HRS is the preeminent professional group representing more than 4,500 specialists in cardiac pacing and electrophysiology, consisting of physicians, scientists and their support personnel. HRS’ members perform electrophysiology studies and curative catheter ablations to diagnose, treat and prevent cardiac arrhythmias. Electrophysiologists also implant pacemakers and cardioverter defibrillators (ICDs) in patients who have indications for these life-saving devices. After device implantation, heart rhythm specialists then monitor these patients and their implanted devices.
It is our interpretation, that the proposed encounter-based composite APC is appropriate, as it will provide a single payment for certain common combinations of component cardiac electrophysiologic services performed on the same date of service, and enables CMS to use more valid and complete claims data to establish payment rates that will better capture the costs of these combination services.
CMS is also proposing to unconditionally package other CPT codes under the grouping of intra-operative services for the CY 2008 OPPS. These codes (93609, 93613, 93621, 93622, 93623 and 93662) are all CPT add-on codes that are often reported with cardiac electrophysiologic evaluation and ablation services. We are concerned, however, with the packaging of intracardiac echocardiography (ICE) (CPT 93662) which is reported as an add-on code for cardiac electrophysiology and interventional cardiology procedures that require a transseptal approach. For CPT 93621, 93622, 93651 or 93652, ICE is used to identify the area of the atrial septum where needle puncture can be safely performed and thus significantly reduce the risk and complications from the procedure. ICE is also a valuable tool in guiding the safe delivery of ablation lesions, and for monitoring of possible pericardial effusion. ICE is currently paid separately under APC 0670 with a payment rate of $1984.52. This is a low volume procedure offered only in a limited number of hospitals which provide the most state-of-the art care to the most complex patients; therefore, we believe that packaging this low-volume procedure will contribute inadequately to the medians of the composite APC or to the individual APC medians. Furthermore, the impact of the packaged payment for this supportive procedure will be concentrated in the small subset of hospitals that have invested in this expensive technology. We recommend that this procedure continue to be paid separately under the OPPS for CY 2008.
In the proposed rule, CMS indicates that the proposed composite APCs may serve as a prototype for future creation of more composite APCs, through which OPPS payment could be provided for other types of services in the future. While we believe that this approach may be appropriate where the claims data show that combinations of services are commonly furnished together, we recommend that CMS proceed with caution regarding broad application of this methodology. Any further development of composite APCs should be accompanied by a clear, transparent process and data for identifying and calculating future composite APCs should be included with documented justifications. Additionally, it is important that composite APCs are designed in a manner that sufficiently accounts for the resources associated with performing the common combinations of services.
HRS appreciates this opportunity to offer our comments. If you have any specific questions regarding our recommendations, please contact Lisa Miller-Jones, Director of Reimbursement and Regulatory Affairs at (202) 464-3433 or LMiller-Jones@HRSonline.org.
Sincerely,
Bruce D. Lindsay, MD, FHRS
President, Heart Rhythm Society
