AMDA has submitted comments on the Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rule Making entitled “Medicare Program; Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2010.” AMDA focused its comments on the Physician Practice Information Survey, consultation services, telehealth services, electronic prescribing, and the Physician Quality Reporting Initiative.
Physician Practice Information Survey Data: AMDA supports the proposal to continue using the practice expense per hour that was developed using the supplemental survey data of the Physician Practice Information Survey (PPIS).
The PPIS data resulted in a 12%–19% increase in practice expense for nursing facility services. However, AMDA stated that societies should be able to provide supplemental data to address concerns with data limits and methodology concerns.
Consultation Services: AMDA supports the proposal to no longer recognize the billing codes for consultation services (except for telehealth consultations), while acknowledging that several AMDA reviewers felt that the deletion of the consultative codes may adversely affect specialists' willingness to make consultative visits in the nursing facility. Under the proposal, physicians would bill an initial hospital care or initial nursing facility care code for their first visit during a patient's admission to the hospital or nursing facility in lieu of the consultation codes these physicians may have previously reported.
Skilled Nursing Facilities (SNF) and Medicare Telehealth Services: AMDA also agrees with the proposal not to include SNF visits for telehealth services. AMDA stated strong agreement with CMS's statement that the complexity of care for these patients warrants direct personal contact. AMDA also agreed with the agency's statement that SNF patients are comparable to hospital patients in their care needs.
Expanding the E-Prescribing Measure Denominator to Include Nursing Facility Services and Home Visits: AMDA supports CMS's proposal to expand the electronic prescribing measure denominator to include nursing facility services (99304–99316) and home visits (99341–99350) for 2010. However, AMDA warned that some of the arguments on infrastructure and process that CMS made in the 2005 E-Prescribing and the Prescription Drug Program; Final Rule (when the agency initially excluded these codes) still hold true. AMDA further recommended that CMS expand the denominator to include the domiciliary codes (99324–99337). AMDA also supports the change to reporting only 25 individual cases.
Physician Quality Reporting Initiative (PQRI): AMDA supports the move toward registry-based reporting through qualified registries. However, AMDA urged CMS to be judicious in its implementation. CMS proposed to significantly limit the claims-based reporting mechanism and move toward the registry-based reporting beyond 2010. AMDA commented: “While we believe that the move toward registry based reporting will streamline the reporting process and encourage the adoption of electronic health records, many nursing facilities as well as small and solo practices are forced to continue with claims-based reporting because they do not have the necessary technology for registry-based reporting.”
The final rule is expected to be published by Nov. 1.
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