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CMS Payment Policy Proposals: The Potential Effect on You

On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) released the CY 2019 proposed rule for the Medicare Physician Fee Schedule (MPFS). Several components of the proposed rule have the potential to affect your practice and patients, which necessitated this late-breaking Panel Presentation. CMS is currently reviewing the more than 15,000 comments it received on the proposed rule.

The AAO-HNS submitted its 26-page comment letter to CMS on September 10, outlining what the Academy does and doesn’t support. Comments focused on proposed changes to documentation requirements, coding and payment for Evaluation and Management (E/M) services, application of the multiple procedure payment reduction (MPPR) to E/M services, and the pricing and composition of balloon sinus surgery kits. To view the Academy’s comment letter, visit www.entnet.org/advocacy.

In Tuesday’s session “How the CMS Proposed Rule Affects Your Practice and Patients,” a panel, including AAO-HNS/F CEO/EVP James C. Denneny III, MD, Robert A. Glazer, MPA, CEO, ENT and Allergy Associates, LLP, and a CMS representative, explained the potential impact of the proposed rule on the specialty.

Barbara J. Connors, DO, MPH, CMS Chief Medical Officer for Region III, shared details on the agency’s “Patients Over Paperwork” initiative to reduce regulatory burdens on providers, allowing more time with patients. While the Academy expressed support for the goal of this initiative during yesterday’s panel, concerns were expressed about CMS’ proposal to collapse payment rates for E/M services from five levels to two, as well as payment reductions for procedures reported on the same day as E/M services.

The final rule is expected to be released next month. While the AAO-HNS and others in the physician community are strongly urging CMS to reconsider (or reject) some of its more concerning proposals, it is important for practicing physicians to know about these potential changes in case they are approved.