The Society for Vascular Surgery (SVS) has submitted comment letters to the Centers for Medicare & Medicaid Services (CMS) on two proposed rules that directly affect SVS members: the Medicare Physician Fee Schedule and the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (HOPPS).
CMS issued the proposed rules in early August. They will be finalized on or around Dec. 1 and effective on Jan. 1, 2021. “The letters provide CMS with our Society’s strong and detailed responses to each vascular policy point in the proposed rules,” said Matthew Sideman, MD, chair of the SVS Policy and Advocacy Council.
The proposed Physician Fee Schedule rule includes cuts that that would reduce total payments to vascular surgeons of 7%.
“These rules include cuts that will have a massive impact on vascular surgery practices for years to come,” said Sideman.
“We are fighting back with these letters, plus a partnership with 11 other surgical societies and with outreach to our own members to contact their legislators.”
The SVS letter also contains comments on the proposed rule for Quality Reporting Programs.
Physician Fee Schedule
The SVS strongly opposes the reduction in the conversion factors, from $36.09 this year to $32.26. This is lower than the 1994 factor, which would be approximately $58 in today’s dollars. This cut, paired with upcoming changes in the office/outpatient evaluation and management values in the global codes, could force surgeons who rely on providing care to Medicare patients to be unable to continue to practice.
SVS also opposes other details in the proposed rule, including the E/M Inherent Complexity Add-on Code and CMS’s establishment in global services of a two-tiered system for evaluation and management services.
SVS offered detailed comments on toe amputation services, supply pricing and the technical expert panel related to practice expense.
The letter also addresses the Quality Payment Program, urging CMS to extend flexibility on the “extreme and uncontrollable circumstances hardship exception” through at least 2021, because of the COVID public health emergency and also agrees that CMS should delay the timeline for implementation of any Advanced Alternative Payment Models (AMPs) until at least 2022.
Other issues also are addressed. Read the complete letter at vsweb.org/21FeeSked.
HOPPS
SVS opposed CMS’ proposal to eliminate the Inpatient Only list over the course of three years. Doing so will “increase patient copayments for many procedures while increasing patient risk.
In contrast, SVS does support an annual process whereby stakeholders nominate services for removal from the IPO list, and due consideration is given to patient safety and patient financial burden.”
The letter also addresses other topics, including changes to the Ambulatory Surgery Center list of covered surgical and dialysis vascular access payments. Read the complete letter at vsweb.org/21HOPPS.
