HRS Leads Opposition to CMS CY23 Reimbursement Cuts
The chronological updates below reflect HRS' efforts to restore fair reimbursement for ablation services in 2023.
The chronological updates below reflect HRS' efforts to restore fair reimbursement for ablation services in 2023.
HRS Nominates Ablation Add-On Codes as Potentially Misvalued
February 10, 2023
In continuation of the Society’s advocacy efforts, ablation add-on CPT codes 93655 and 93657 were submitted for review under the Centers for Medicare & Medicaid Services (CMS) Potentially Misvalued Codes Initiative. In the 2023 Medicare Physician Fee Schedule final rule, CMS accepted the RUC-recommended work RVUs for ablation codes 93653, 93654, and 93656, but not for the two add-on codes. The nomination urges CMS to accept the RUC-recommended work values for all ablation services.
Negotiating with Your Employer for RVU-Based Physician Compensation for Ablation Services
January 3, 2023
The Society has prepared RVU and payment rate tables to assist employed electrophysiologists in negotiating physician compensation for ablation services. Payment rates for SVT, VT, and AF ablation services have drastically decreased under the Medicare Physician Fee Schedule from 2021 to 2023, but hospital facility payment rates have steadily increased.
This comparison of physician and facility payments is essential to understand because ablation services are projected to increase by over 50% by 2030. So, while physician reimbursement from the CMS for ablation has decreased significantly, Medicare payments to hospitals continue to increase for these critical therapies.
It is important that healthcare systems ensure fair reimbursement for electrophysiologists to safeguard the ability to meet future ablation demand.
Omnibus Spending Bill Partially Reduces Medicare Physician Payment Cuts for 2023 and 2024
January 3, 2023
On December 19, 2022, Congress passed the Consolidated Appropriates Act of 2023, which provides $1.7 trillion in spending for various healthcare provisions and other policy issues. Before the bill's passage, physicians faced an -8.5% total Medicare payment reduction starting January 1, 2023. The legislation partially reduces Medicare Physician Fee Schedule (MPFS) payment cuts over the next two years by increasing the conversion factor (CF) for 2023 and 2024. Originally finalized as a -4.5% decrease, the CF will increase by 2.5% for 2023, resulting in a smaller cut of -2% for this year. The legislation also includes a 1.25% increase to the 2024 CF to offset additional cuts expected for that year. In addition, the legislation delays the statutory 4% Pay-As-You-Go (PAYGO) sequestration for fiscal years 2023 and 2024.
For those participating in the Advanced Alternative Payment Model (AAPM) track of the Medicare Quality Payment Program (QPP), the bill extends incentives that were set to expire this year through the 2025 payment period at 3.5%, as opposed to the current 5%.
The bill also extends several Medicare telehealth flexibilities authorized for the COVID-19 Public Health Emergency for two years through December 31, 2024, including:
- Waivers to the geographic and originating site restrictions
- Expansions to the list of eligible practitioners
- Eligibilities for federally qualified health centers and rural health clinics
- Allowing telehealth to be provided through audio-only telecommunications
- Allowing telehealth to be used for a required face-to-face encounter before the recertification of a patient's eligibility for hospice care
- Delaying the in-person visit requirement before a patient receives telemental health services
Other healthcare provisions in the omnibus appropriations bill include:
- Allowing states to begin processing Medicaid redeterminations on April 1, 2023, while phasing down the COVID-19 public health emergency (PHE)-related enhanced Federal Medical Assistance Percentage (FMAP);
- Requiring state Medicaid programs to provide 12 months of continuous coverage for children and permanently allow states to offer 12 months of coverage for postpartum women;
- Providing 200 additional Graduate Medical Education (GME) slots, at least half of which will be dedicated to psychiatry and psychiatry subspecialty residencies, among other workforce provisions;
- Taking several steps to improve access to behavioral health services;
- Making improvements to the government's ability to prepare for future emergencies; and
- Delaying for a year reduction in payment for clinical laboratory tests and data reporting requirements under the Clinical Laboratory Fee Schedule.
In addition, the bill provides funding for other healthcare and research provisions highlighted below:
- $47.5 billion for the National Institutes of Health;
- $9.2 billion for the U.S. Centers for Disease Control and Prevention;
- $1.5 billion for the Advanced Research Projects Agency for Health (ARPA-H) fight against cancer; and
- $950 million for the Biomedical Advanced Research and Development Authority to bolster national health security.
Not included in the bill was a provision to direct the Centers for Medicare & Medicaid Services (CMS) to adopt the RUC-recommended values for add-on ablation services (Ablate Arrhythmia 93655 and Treat Additional AF Foci 93657).
HRS Seeking Legislative Solutions to CMS Ablation Cuts
November 22, 2022
The Centers for Medicare & Medicaid Services (CMS) published its physician payment final rule on November 1, 2022, and ablation reimbursements came up short of expectations. HRS has been busy considering the next steps in advocating for its members. HRS recognizes and appreciates the hard work of its members and their patients in influencing CMS to amend their proposals and accept most of the AMA/Specialty Society RVS Update Committee (RUC) recommendations.
The regulatory cycle to influence CMS for 2023 has closed, so HRS is working on alternative strategies, which include involving Congress to enact a legislative change. While the Society continues its long-term efforts to restore fair compensation, HRS is currently focused on a more achievable ask within the short window of time remaining to impact 2023 reimbursement.
With help from Capitol Counsel, the Society's advocacy partner on the Hill, HRS is finalizing sign-on letters from Senate and House representatives pushing for the inclusion of language in a pending healthcare funding bill to require the RUC-approved values for the add-on codes. While CMS' final rule included RUC-recommended RVUs for SVT, AF, and VT ablation, they did not accept the RUC recommendations for add-on codes. The CMS final rule of 5.5 RVUs for each of the two add-on codes does not align with the RUC's recommendation of 7.0 RVUs each.
HRS plans to send these letters in early December. To help facilitate your participation, Capitol Counsel is drafting language for you to send to your representatives via SaveAblation.org. HRS will notify you when the updated language is available on SaveAblation.org.
As previously mentioned, the Society will expand its health policy education curriculum to help its members better understand the impacts of these recent cuts, including discussion guides outlining the payment valuation process and its role in your daily practice.
The EP community has a long road ahead to ensure access for patients and fair reimbursement in the field. Still, HRS is committed to achieving short-term gains and long-term access to ablation and other critical services its members provide.
HRS Presidential Update: The Final Ruling
November 3, 2022
HRS President Andrew D. Krahn, MD, FHRS, responds to the final ruling by CMS for ablation services in 2023. On November 1, 2022, CMS released the final CMS 2023 Medicare Physician Fee Schedule, which adopted the AMA/Specialty Society RVS Update Committee (RUC) recommendations for AF, VT, and SVT ablation. However, there is still work to be done, and HRS will continue to fight for fair reimbursement through legislative channels and compensation reform.
Heart Rhythm TV Update: The Final Ruling
November 2, 2022
CMS Finalizes RUC Recommendations for AF, VT, and SVT Ablation
November 1, 2022
The Centers for Medicare & Medicaid Services (CMS) has finalized the AMA/Specialty Society RVS Update Committee (RUC) recommendations for Medicare electrophysiology ablation services in 2023 despite the unprecedented opposition efforts by the Heart Rhythm Society (HRS), the American College of Cardiology (ACC), the newly formed EP Advocacy Foundation (EPAF), patient organizations such as StopAfib.org and the Arrhythmia Alliance, Members of Congress, and other stakeholders.
HRS and the American College of Cardiology have issued the following statement in response to this final ruling:
While the changes the Centers for Medicare & Medicaid Services (CMS) made in response to feedback from the Heart Rhythm Society (HRS), American College of Cardiology (ACC), members of Congress, and other stakeholders are appreciated, HRS and ACC remain disappointed that the agency did not go further in amending the proposed cuts for key electrophysiology ablation services to reflect higher values derived within the established RUC survey process, recognizing the high degree of skill and a lengthy period of training required to perform these complex services, the enhanced safety despite increasingly sick patients, improved quality outcomes, and greater clinical value.
These ongoing cuts, as well as structural cuts to all Medicare services, continue to threaten patient access to important, high-value cardiovascular services and underscore the need for not just short-term fixes but long-term overarching reimbursement reform.
Heart Rhythm Society
Andrew Krahn, MD, FHRS, President
American College of Cardiology
Edward T.A. Fry, MD, FACC, President
While HRS leadership appreciates CMS' willingness to reconsider and return to recommendations of the long-accepted AMA/Specialty Society RVS Update Committee (RUC) process, HRS remains disappointed that CMS has not gone far enough in acknowledging:
- The high degree of skill and the lengthy period of training required to perform ablation services
- The complexity and risk involved in these procedures
- Enhanced safety achieved despite increasingly sick patients
- Improved quality outcomes
- The documented cost savings for patients who have undergone ablation
- Limiting patient access to effective ablation services, particularly for underserved communities
- The impact of discouraging talented trainees from the extended training required for electrophysiology when the field is already struggling to meet a rising demand
HRS will continue a determined effort to collaborate with all stakeholders seeking legislative intervention to restore fair compensation and protect patient access to ablation services for 2023 and beyond. The severity of these cuts clearly shows that the system is not working. HRS will continue working with legislators and the greater medical community to pursue a better path forward.
HRS would like to thank the thousands of members and patients who actively responded by submitting comments to CMS and contacting their legislators for support. You have made a difference. CMS has responded, and we now have the attention of many legislators and policymakers, plus your continued support to keep pressure on CMS.
HRS will continue to provide updates on this webpage, as well as via Heart Rhythm TV, HRS Communities, social media channels, and email. The Society also plans to offer educational support and resources to help you navigate through the impact of these cuts as we continue this fight.
Urge Congress to Protect Access to Ablation Procedures
October 21, 2022
This year, the Centers for Medicare & Medicaid Services (CMS) implemented substantial payment cuts to ablation procedures, and CMS is proposing another round of deep payment cuts for the calendar year 2023.
Currently, as many as 6 million Americans suffer from atrial fibrillation, many of whom would benefit from catheter ablation. CMS' unjustified and irrational cuts could impact access to ablations, particularly for underserved minorities for whom issues of healthcare access already pose a problem.
The EP community must tell members of Congress just how detrimental these cuts will be — potentially limiting healthcare access for some of the nation's most vulnerable patients. If you have not already done so, please immediately email your members of Congress to help preserve access to ablation procedures.
SaveAblation.org, launched by the EP Advocacy Foundation and endorsed by HRS, is an easy-to-use tool to email your local congressional representatives.
Using the email tool is quick and easy:
- Verify your address to pull up your Congressional representatives' contact information.
- Use the editable pre-written language as is, or customize it with your personal concerns.
- Enter your contact information and click send.
Please send an email today to your elected member of Congress and urge them to take action to halt these Medicare payment cuts.
Heart Rhythm TV
October 17, 2022
HRS Presidential Update
October 14, 2022
HRS President Andrew D. Krahn, MD, FHRS, provides a weekly recap of the Society's continuing efforts to fight CMS proposed CY23 cuts to ablation services, including recent discussions with:
- The White House Office of Management and Budget (OMB)
- Francis "Frank" Biden, brother of U.S. President Joe Biden
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. These calls included members of the Society, HRS Board of Trustees, Health Policy and Regulatory Affairs Committee, HRS staff, and HRS' advocacy partner, Capital Counsel.
Heart Rhythm TV
September 30, 2022
Joint Patient and Provider Letter to Congressional Leaders
September 29, 2022
HRS penned a letter to congressional leaders Mitch McConnell, Nancy Pelosi, Charles Schumer, and Kevin McCarthy to stress the problems with CMS' proposed cuts to ablation services for 2023. This letter was signed by ACC, the Electrophysiology Advocacy Foundation (EPAF), the Arrhythmia Alliance, StopAfib.org, and the AF Association.
Dear Leader McConnell, Leader Schumer, Speaker Pelosi and Leader McCarthy:
On behalf of the undersigned patient and provider organizations, we are strongly concerned that a proposed Physician Fee Schedule (PFS) rule published by the Centers for Medicare and Medicaid Services (CMS) on July 7, 2022, will result in the inability of Medicare beneficiaries to access cardiac ablation, a lifesaving, cost effective, and highly specialized cardiac procedure for treating the growing incidence of atrial fibrillation (AF).
This minimally invasive family of procedures (five distinct services), which help control abnormal heart rhythms and limit the need for open heart surgery and long-term drug therapy, will be cut by as much as 40 percent over two years by this proposed PFS rule. In addition to reducing open-heart surgeries, a 3-year studyi showed that hospital admissions for patients treated with ablation were reduced by a substantial 64 percent, and emergency department visits were reduced by over 50 percent. For patients treated with cardiac ablation, there was a total savings on the cost of AF management of $850 per patient per month at one year and $546 per patient per month at three years.
The CMS-proposed payment cuts for ablation services could also profoundly impact access to these services by disincentivizing entrant physicians into the very specialized training of electrophysiology (EP) for treating AF. In the U.S., there are only approximately 3,000 physicians certified in EP, while the number of patients with AF is expected to double from 6 million to 12 million by 2030. Training fellowships for EP are already facing unfilled opportunities due to the additional two years of specialized training required for these physicians. The CMS rule’s steep reductions, if implemented, will present another barrier to meeting the growing demand for these cost-effective and life- enhancing procedures for all Medicare AF patients, including racial and ethnic minorities who have disproportionately worse outcomes related to cardiac rhythm disorders.
It is our understanding that, in developing its recommendation, CMS errantly relied on a comparison to the time necessary for a dissimilar procedure – lower limb revascularization. The risk of working on an isolated area of the leg versus ablating tissue in a beating heart (with adjacent vital structures) seems incomparable from a clinical or patient perspective. For the sake of Medicare AF patients, an appropriate review should be conducted using relevant data that reflects the full scope of physician resources – including work, intensity, complexity, and necessary skill for cardiac ablation – with the goal of restoring payments to be more consistent with 2021 reimbursement.
As Congress works toward a value-based framework for Medicare, it is our hope that it will guide CMS toward services like cardiac ablation that reduce hospital admissions and emergency department visits. Failing to do so could jeopardize cost-effective and life-saving treatments for Medicare beneficiaries and the supply of highly trained certified cardiac physicians.
American College of Cardiology
Electrophysiology Advocacy Foundation (EPAF)
Heart Rhythm Society
HRS Presidential Update
September 27, 2022
HRS President Andrew D. Krahn, MD, FHRS, provides a weekly recap of the Society's continued fight against CMS' proposed CY23 cuts to ablation services, including immediate and long-term objectives:
- 50+ congressional meetings coordinated by HRS and Capital Counsel
- Additional congressional meetings being held by ACC and the EP Advocacy Foundation (EPAF)
- Patient advocacy group support from StopAFib.org and the Arrhythmia Alliance
- Templated and automated emails to Congress available on SaveAblation.org, initiated by EPAF and endorsed by HRS
- HRS Board meeting with Rep. Michael C. Burgess, MD (R-TX-26)
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 email@example.com to receive preparatory information.
Heart Rhythm TV Update
September 23, 2022
HRS Presidential Update
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 Presidential Update
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
August 19-23, 2022
Congressional Outreach Opposing CMS’ Proposed Payment Cuts to Ablation Services
A 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.
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 firstname.lastname@example.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
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 email@example.com.
Heart Rhythm TV
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.
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.