HRS Leads Opposition to CMS Reimbursement Cuts in 2023 | Heart Rhythm Society

HRS Leads Opposition to CMS Reimbursement Cuts in 2023

Despite the combined advocacy efforts of HRS, ACC, and AMA RUC since July 2021, the Centers for Medicare & Medicaid Services (CMS) disregarded the recommendations of HRS, ACC, and AMA RUC to reduce ablation reimbursement in 2022 and attempts to enact additional cuts in 2023.

Join Congressional Meetings

If you are interested in participating in one of the upcoming congressional calls, please email Tim Gregory, HRS' Chief Learning Officer, to receive preparatory information.

Monday, September 26

2:00 PM ET: Rep. Brownley (D-CA-26)
2:30 PM ET: Rep. Lawson (D-FL-05)
3:00 PM ET: Rep. Cathy McMorris Rodgers R-WA
3:30 PM ET: Rep. Cardenas (D-CA-29)
4:00 PM ET: Rep. Allred (D-TX-32)

Tuesday, September 27

2:00 PM ET: Rep. Fitzpatrick (R-PA-01)
2:30 PM ET: Rep. Herrera Beutler (R-WA-03)
3:00 PM ET: Sen. Tim Scott (R-SC)
4:00 PM ET: Sen. Kelly (D-AZ)

Wednesday, September 28

2:00 PM ET: Sen. Wyden (D-OR)
4:00 PM ET: Sen. Casey (D-PA)
4:30 PM ET: Sen. Warren (D-MA)

Thursday, September 29

2:00 PM ET: Rep. Calvert (R-CA-42)
2:30 PM ET: Rep. Blunt Rochester (D-DE-At-Large)

Wednesday, October 5

2:00 PM ET: Rep. Doggett (D-TX-35)

 

Updates are listed in chronological order, starting with the most recent.

Congressional Meetings to Fight CMS Reimbursement Cuts

September 23, 2022

Beginning in August, the Society embarked on a massive grassroots effort to contact Congressional representatives about CMS' deep 2022 and proposed 2023 cuts to ablation service reimbursements. 
 
In the last two weeks alone, members of the HRS Board of Trustees, Health Policy and Regulatory Affairs Committee, HRS staff, and HRS' advocacy partner, Capital Counsel, have conducted 41 meetings with members of Congress:

Thursday, September 8 
Jack Boyd (Sen. Portman (R-OH))

Friday, September 9
Rep. Brady (R-TX-08)
Rep. Miller-Meeks (R, IA-02)
Rep. Gomez (D, CA-34)
Rep. Butterfield (D-NC-01)

Monday, September 12
Sen. Cantwell (D-WA)
Sen. Blumenthal (D-CT)
Rep. Aderholt (R-AL-04)
Rep. Posey (R-FL-08)

Tuesday, September 13
Sen. Young (R-IN)
Sen. Toomey (R-PA)
Rep. Balderson (R-OH-12)

Wednesday, September 14
Sen. Grassley (R-IA)
Sen. Menendez (D-NJ)
Sen. Lankford (R-OK)
Sen. Burr (R-NC)
Sen. Baldwin (D-WI)

Thursday, September 15
Rep. Bost (R-IL-12)
Sen. Rosen (D-NV)
Sen. King (I-ME)
Sen. Hassan (D-NH)

Friday, September 16
Rep. McBath (D, GA-06)

Monday, September 19 
Rep. Demings (D-FL-10)
Sen. Stabenow (D-MI)
Rep. Dave Joyce (R-OH-14)

Tuesday, September 20
Sen. Hickenlooper (D-CO)
Sen. Cornyn (R-TX)
Sen. Lujan (D-NM)

Wednesday, September 21
Rep. Auchincloss (D-MA-04)
Sylvia Lee (Sen. Sinema (D-AZ)
Sen. Bennet (D-CO)
Rep. Burgess (R-TX)

Thursday, September 22
Rep. Luetkemeyer (R-MO-03)
Rep. Moore (D, WI-04)
Rep. Cline (R-VA-06)
Sen. Murray (D-WA)
Sen. Duckworth (D-IL)

Friday, September 23
Paul Hartman (Rep. Latta (R-OH-05)
Kevin Gannon (Rep. Garbarino (R-NY-02)
Corey Linehan (Sen. Coons (D-DE)
Audrey Smith (Sen. Manchin (D-WV)

The participation of HRS members from the same state or district as the member of Congress in the meeting is powerful. If you are interested in joining one of the upcoming calls (scroll to the top of this page to view upcoming calls), please email Tim Gregory, HRS' Chief Learning Officer, at tgregory@hrsonline.org to receive preparatory information.

Heart Rhythm TV Update

September 23, 2022

 

HRS Continues Fight Against CMS Cuts on the Hill

September 16, 2022

HRS President Andrew D. Krahn, MD, FHRS, provides an update on the continued fight against the CMS proposed CY23 cuts to ablation services. To summarize:

  • 16 productive meetings with U.S. Representatives were conducted and included our advocacy partner on the Hill, Capitol Counsel
  • 16 additional meetings with U.S. Representatives are scheduled over the next 10 days
  • 50 meeting invites sent to additional U.S. Representatives
  • 300% increase in advocacy support for FY23 approved by the HRS Board of Trustees

Heart Rhythm TV Updates

September 15-16, 2022

HRS FY 2023 Budget Approved with Increased Advocacy Support

September 14, 2022

The HRS Board of Trustees approved the Society's FY 2023 budget last week, with significant increases earmarked to support advocacy for fair reimbursement of heart rhythm services. A new advocacy strategy that includes both regulatory and legislative elements will address not only the current proposed cuts to ablation but also threats to reimbursement of other services provided by heart rhythm specialists.

Heart Rhythm TV Updates

September 2-9, 2022

HRS Reaffirms Position to Demand Fair Reimbursement

September 2, 2022

Earlier this week, HRS President Andrew D. Krahn, MD, FHRS, convened another emergency Board of Trustees meeting to review HRS' official position and strategy for opposing these draconian actions. After considering all the discussions that have taken place across various channels (e.g., conversations with ACC, the Discord discussion group, HRS Communities, etc.), the Society reaffirmed its decision to demand fair reimbursement comparable to 2021 for physicians performing these ablation services.

The deadline for the EP community to express outrage and concerns to CMS is quickly approaching.

The Society strongly encourages you to submit your comments to CMS before the September 6 deadline. To help you craft your letter, please utilize the following resources:

We are in this fight together. To win this battle, we must band together to stop CMS from enacting these proposed cuts.

Join the Fight to Stop Payment Cuts to Ablation Services: Letter Template for Submitting Comments

August 30, 2022

The Centers for Medicare & Medicaid Services (CMS) has proposed to cut payment for SVT, VT, and AF ablation services effective January 1, 2023.
 
Over 300 members of the EP community have written to the CMS opposing the proposed payment cuts. If you have not already done so, HRS urges you to join the fight and send comments to CMS using this comment letter template by September 6, 2022.
 
To submit your comments to CMS, please follow the instructions below:
 
The "Comment" button for the CY2023 Medicare Physician Fee Schedule can be found on the following pages of regulations.gov:

  • Docket Details page when a document within the docket is open for comment,
  • Document Details page when the document is open for comment, and
  • Document Search Tab with all search results open for comment displaying a "Comment" button.

Clicking "Comment" on any of the above pages will display the comment form. You can enter your comment on the form, attach files (maximum of 20 files up to 10MB each), and choose whether to identify yourself as an individual, an organization, or anonymously.


Be sure to complete all required fields depending on which identity you have chosen. Please note that information entered on the web form may be viewable publicly. Once you have completed all required fields and chosen an identity, the "Submit Comment" button is enabled. Upon completion, you will receive a Comment Tracking Number for your comment.
 
We are in this fight together. If we are to achieve any success in this battle, it will take an extraordinary effort from HRS members to contact CMS.

Heart Rhythm TV Updates

August 19-23, 2022

Congressional Outreach Opposing CMS’ Proposed Payment Cuts to Ablation Services

Christopher F. Liu, MD, FHRS - Health Policy and Regulatory Affairs Committee ChairA message from Christopher F. Liu, MD, FHRS, Health Policy and Regulatory Affairs Committee Chair
August 19, 2022

Throughout August, a leadership delegation from the Heart Rhythm Society (HRS) and the American College of Cardiology (ACC) conducted a series of meetings with individual Congressional staffers to discuss one topic — our dire concerns with the Centers for Medicare & Medicaid Services’ (CMS) proposed deep cuts to ablation service reimbursements.

Joint leadership included myself, Amit J. Shanker, MD, FHRS; Joseph E. Marine, MD, FHRS; Samuel O. Jones, MD, MPH, FHRS; and Jim W. Cheung, MD, FHRS. Our contingency met with staffers from the congressional offices of Rep. Richard Neal (D-MA, Chairman of the House Ways and Means Committee), Rep. Brad Wenstrup (R-OH), Rep. Mariannette Miller-Meeks (R-IA), Rep. Ami Bera (D-CA); Rep. Larry Bucshon (R-IN), Rep. Raul Ruiz (D-CA); Rep. Neal Dunn (R-FL), and Rep. Kim Shrier (D-WA). I want to note that all Representatives, except Rep. Neal, are physicians; therefore, they have good context for our conversations. With the involvement of the HRS Board of Trustees and the Society’s advocacy partner, Capitol Counsel, additional meetings with other members of Congress are in the works.

We are in continued conversations with these Representatives, which is why I am reaching out to you right now — please help us fortify our message to Congress.

May I ask you to contact your Congressional offices today to reinforce this issue's importance and urgency, especially if you live in one of the above districts? Please use the HRS Ablation Reimbursement Brief in your outreach.

This one-page document succinctly outlines:

  • EP conditions, patients, and the complexity of ablation treatments
  • The value proposition and health equity considerations
  • Numerous flaws in CMS’ process
  • Unintended consequences of these cuts
  • How to make your voice heard for maximum impact

As a U.S. member of our Society, I am asking you to contact your Congressional representatives and instruct them to engage with CMS and direct CMS to stop the proposed cuts that are irrational and unjustified. Physician payment overall (and budget neutrality) is the bigger issue and needs to be fixed, but these proposed cuts for ablation services need to be addressed urgently to preserve patient access.

We are in this fight together. If we are to achieve any success in this battle, it will take an extraordinary effort from our U.S members and our partners to contact Congress.

In closing, I would be remiss if I did not take a moment to thank the entire Health Policy & Regulatory Affairs Committee (past and present) for their incredible dedication as volunteers throughout the years and especially during this challenging time.

Kind regards,

Christopher F. Liu, MD, FHRS
Chair, Health Policy and Regulatory Affairs Committee

HRS Updates Position on CMS Proposed 2023 Cuts for Ablation Reimbursement

August 18, 2022

After several weeks of discussion, significant feedback from membership, and guidance from the Society’s recently retained legislative advocacy firm, Capitol Counsel, the Board of Trustees has revised the Heart Rhythm Society's (HRS) position on the Centers for Medicare & Medicaid Services (CMS) proposed 2023 cuts to reimbursement for ablation services.
 
View and download the new HRS Ablation Reimbursement Issue Brief and take action today by sharing it with your representatives in Congress.

The Board of Trustees previously aligned with the American College of Cardiology (ACC) in demanding that CMS accept the AMA RVS Update Committee (RUC) recommendation, which still represented significant reductions in reimbursements for ablation services. In the 2023 Medicare Physician Fee Schedule proposed rule, CMS would cut a select set of procedures (five distinct services) by upwards of 40% over two years. While marginally less than the CMS proposed cuts for ablation, the RUC recommendation still represented significant cuts. These steep reductions are not only untenable but also unsustainable for the profession. They will jeopardize access to these critical services for thousands of Medicare beneficiaries, particularly those in many urban and rural communities.
 
While many members have called for HRS to "reverse" these cuts or return to the 2021 reimbursement model, the reimbursement structure has been modified too significantly for those options to be considered. Instead, the Board of Trustees is seeking fair reimbursement comparable to 2021 for physicians that perform these ablation services.
 
The primary flaw of CMS' new reimbursement proposal is that it is predominantly based on procedure time. CMS fails to recognize other essential circumstances, such as intensity, complexity, and the necessary skills required to perform the procedures.
 
While not wholly aligned with the Society's revised position at this time, ACC has offered to continue supporting HRS in this matter where there is alignment. ACC has requested that CMS consider holding at the 2022 reimbursement rates with an absolute minimum of accepting the RUC recommendations.

Take Action Today

CMS will not likely consider the Society's position without significant influence from Congress. Thus, HRS members must reach out to their representatives directly. Please utilize this HRS Ablation Reimbursement Issue Brief, which outlines the issue, provides background information, and details the Society's new goal and recommendation.

If you do contact a member of Congress, the Society asks that you notify HRS at policy@hrsonline.org.

In collaboration with Capitol Counsel, HRS is preparing a detailed response to CMS that will outline the details of our specific recommendations well in advance of the September 6th deadline for responses.

A tremendous amount of time and energy has already been expended over the past several months to address this critical matter. The Board of Trustees would like to thank the members of the HPRAC, the new CMS Strategic Advisory Task Force, and countless others for lending your efforts in this fight.

Heart Rhythm TV Updates

August 5-15, 2022

Capitol Counsel, LLC Selected as Partner to Fight Proposed CMS Cuts

August 2, 2022

Last Thursday, the Heart Rhythm Society selected Capitol Counsel, LLC as a partner in the fight against the proposed CMS ablation fee cuts. Capitol Counsel is a bipartisan and bicameral government relations firm that provides political analysis, strategic advice, and advocacy services to its clients.

The Capitol Counsel team has decades of experience in federal policymaking and politics. Members of their team served as members of Congress, senior congressional staff on key congressional committees, and in senior executive branch positions. They maintain an understanding of the policies shaping the U.S. healthcare delivery system, and have extensive experience with public and private healthcare coverage and payment issues.

Experts in legislative affairs, Capitol Counsel will elevate the Society’s fight against CMS’ proposed cuts through:

  • Development and implementation of a strategic plan of action
  • Tactical advice and guidance
  • Direct advocacy before Congress and the Administration
  • Creation of advocacy materials, talking points, and other relevant charges and tools
  • Political and policy intelligence gathering and analysis
  • Recommendations for political giving program
  • Assistance in assembling status updates for the leadership and members of Congress

Additional details will be shared as they become available.

To ensure Capitol Counsel is able to support HRS as efficiently and effectively as possible, please do not contact Capitol Counsel directly. Instead, please send your questions and comments to policy@hrsonline.org.

Heart Rhythm TV Updates

July 25 - August 1, 2022

HRS/ACC Joint Call-to-Action Regarding Proposed Ablation Cuts in CMS Proposed CY2023 Rule

July 25, 2022

Last year, despite vigorous opposition from HRS, the American College of Cardiology (ACC), partner organizations, and patients, the Centers for Medicare & Medicaid Services (CMS) reduced payment for ablation services from their 2021 values. The 2022 reductions were the result of the bundling of codes for 3D mapping (93613), left atrial recording (93621), or intracardiac echocardiography (93662) services into the primary CPT codes for supraventricular tachycardia (SVT) (93653) and atrial fibrillation (AF) (93656) without any increases to account for the newly bundled services.

Despite strong advocacy efforts by ACC and HRS on behalf of our members, CMS announced in the CY2023 Medicare Physician Fee Schedule Proposed Rule that it intends to further reduce reimbursement for SVT, ventricular tachycardia (VT), and AF ablations (CPT codes 93653, 93654 and 93656). Additionally, CMS indicated that it will maintain the current reduced values for add-on codes to ablate additional arrhythmias (code 93655) and to treat AF with additional ablation after pulmonary vein isolation (code 93657). While we anticipated some reduction in these code valuations due to the results of the recent RUC surveys, CMS is proposing to reduce payment beyond recommended values negotiated at the RUC.

Why It Matters

These cuts create a new obstacle for electrophysiologists caring for patients with arrhythmias. They are coupled with the troubling trend of ongoing reductions via conversion factor cuts (proposed -4.5% in CY2023), statutory cuts from sequestration and PAYGO rules, and a flat annual payment update that fails to account for significant inflation in practice costs, patient complexity, and enhanced physician work associated with the greater utilization of same-day discharge protocols. The ablation-specific reductions are an alarmingly significant departure from the American Medical Association/Specialty Society RVS Update Committee (RUC) recommended values.

The RUC survey and evaluation process (in which practicing physician feedback is used to create recommended relative values for services) was, in this case, disregarded by CMS, instead using comparator codes that are in no way comparable to the services in question. Despite the AMA Specialty Society RUC making a great effort to recognize and adjust to the new efficiencies of these codes through advanced technology that increases complexity and risk, CMS further reduced the RUC-recommended values by nearly 10% in the 2023 proposed rule following a 26% reduction that was implemented in the 2022 final rule.

Visit ACC's website to learn more.

How Can You Help?

ACC and HRS do not agree with or accept these proposed reductions and will continue advocating aggressively against their enactment, which is scheduled for January 1, 2023. Members of both organizations are urged to utilize ACC's Action Alert system to share their opposition to these reductions through comments to the Agency before the comment period closes on September 6, 2022.

HRS and ACC both support and work to help develop reimbursement models that recognize the reality of limited CMS funding for health services, reward high-quality and high-valued outcomes, align incentives of payers, patients, and providers, and are a fair reflection of clinician work. HRS and ACC will continue to advocate vigorously for our members to mitigate these cuts and will update you accordingly with our efforts and calls for action.

Board of Trustees Meeting to Discuss CMS CY23 Reimbursement Cuts

July 22, 2022

On Wednesday, July 20, 2022, the HRS Board of Trustees convened an unscheduled meeting with several EP reimbursement experts to understand and discuss the Society’s response to the Proposed Rule. The Board authorized funds to hire a lobbying firm to quickly work within the legislative process to convince CMS to accept the RUC recommendations. HRS will also continue to work closely with ACC to activate a grassroots effort to assist you in contacting your legislators to assist with this important message to CMS.
 
HRS will continue to provide frequent communications over the next few months.

HRS to Lead Members in Unprecedented Opposition to CMS 2023 Reimbursement Cuts

July 13, 2022

CMS' proposed reductions for EP services in CY2023 are significant, unprecedented, and unsubstantiated, and HRS neither agrees with nor accepts them. To combat these cuts, HRS will initiate a multi-faceted urgent response strategy, including:

  • Member grassroots campaign to legislators (with specific talking points)
  • Member letter writing campaign to CMS during the comment period (specific talking points will be provided)
  • Member outreach to Hospital Administrators/CEOs (with specific talking points)
  • Continued support and collaboration with ACC and AMA
  • Continued discussions and dialogue directly with CMS
  • Engaging additional professional legislative advocacy advisors (Republican and Democrat)
  • Engaging legal counsel to evaluate legal actions
  • Soliciting support from industry partners
  • Soliciting support from patient organizations such as Arrhythmia Alliance and Stop Afib
  • Providing analysis tools of proposed rule details and points of contention with illustrations to better inform members/partners on the issue
  • Maintaining regular member communications on the CMS reimbursement advocacy actions through Keeping Pace, Inside HRS, Social Media, and Heart Rhythm TV

HRS is committed to aggressively fighting against these reductions and their enactment, scheduled for January 2023.

CMS Releases CY 2023 Medicare Physician Fee Schedule Proposed Rule

July 7, 2022

Since July 2021, the Heart Rhythm Society (HRS), the American College of Cardiology (ACC), and the American Medical Association Relative Value Scale Update Committee (AMA RUC) have aggressively fought against reimbursement cuts put forth by the Centers for Medicare & Medicaid Services (CMS).

Despite vigorous advocacy efforts, CMS disregarded objections from the EP community regarding cuts in ablation reimbursement for CY 2202, resulting in a 34% reduction in EP services effective January 1, 2022. These 2022 reductions were the result of the bundling of mapping and interrogation services into the primary CPT codes without any increases to account for the newly bundled services (CPT 93613/CPT 93621).

With the release of the CY 2023 Medicare Physician Fee Schedule Proposed Rule, CMS is attempting to enact additional cuts in 2023. The CY 2023 proposed rule would:

  • Drastically reduce reimbursement for SVT, VT, and AF ablations (codes 93653, 93654, and 93656)
  • Maintain reduced values for add-on codes to ablate arrhythmias (code 93655) and treat AF ablation (code 93657)

CMS will accept public comments on proposed policy changes until September 6, 2022.