ACC Comments on Proposed OPPS, Medicare Physician Fee Schedule Rules The ACC recently submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on proposed updates to both the 2018 Hospital Outpatient Prospective Payment System (OPPS), as well as the proposed 2018 Medicare Physician Fee Schedule. Final rules are expected in late October. In terms of the proposed OPPS rule, the College’s comments specifically supported the reinstatement of the notice of non-enforcement of the direct supervision instruction for outpatient therapeutic services for critical access hospitals and small rural hospitals having 100 or fewer beds in 2018 and 2019. The College also urged changes to the proposed Imaging Ambulatory Payment Classification (APC) structure in order to maintain payment stability for cardiovascular imaging services. Proposed changes to the Hospital Outpatient Quality Reporting (OQR) Program were also addressed in the comment letter. The College stressed the need for CMS to ensure that social risk factors do not undermine evidence-based measures in the determination of quality care. The ACC recommended the Agency align any efforts to incorporate social risk factors in the program with similar efforts already underway in other Medicare payment programs. The ACC also requested that CMS continue to consider both the potential limitations in data collection in accounting for social risk factors, as well as the impact of socioeconomic data collection on the patient “The College encourages CMS to maintain a transparent process for engaging stakeholder feedback through future rulemaking and utilization. ... As CMS makes updates to the OPPS, the College asks that the Agency continue to prioritize policies that provide a stable environment for patient access to high-quality, evidence-based cardiovascular care,” said ACC President Mary Norine Walsh, MD, FACC. The ACC’s comments on the proposed Medicare Physician Fee Schedule specifically addressed proposed changes to the new appropriate use criteria (AUC) requirement for advanced imaging services (i.e., SPECT MPI, CT and MR), as well as changes to malpractice and practice expense components of the fee schedule.The comments also touched on recommendations regarding work relative value units for specific codes, payment rates for services provided by off-campus provider-based departments, quality and value program adjustments and reporting, and patient relationship codes to be used in quality reporting. Under the proposed rule, physicians would see a less than 0.1 percent conversion factor payment increase on Jan. 1, 2018. CMS estimates that the physician rule will decrease payments to cardiologists by 2 percent from 2017 to 2018. This estimate predicts a 1 percent reduction to changes in practice expense and a 1 percent reduction to changes in malpractice expense. Additionally, the proposed rule would reduce payment rates for certain items and services furnished by non-grandfathered off-campus hospital providerbased departments from 50 percent of the Hospital OPPS to 25 percent and implement a request for information regarding potential changes to regulations to relieve administrative burdens, among other things. The ACC’s Health Affairs Committee and Advocacy staff continue to advocate for thorough and ongoing educational opportunities and resources for clinicians and hospital administrators to ensure the smooth implementation of these proposed practice changes. Get the latest information through the Advocate newsletter and @Cardiology on Twitter. ACC 2017 Legislative Conference Takes to Capitol Hill With more than 400 attendees from across the United States, the ACC’s 2017 Legislative Conference provided a unique opportunity to raise the College’s profile on Capitol Hill. The event kicked off with the annual ACC Political Action Committee dinner, featuring keynote speaker Nicolle Wallace, an NBC News political analyst and host of MSNBC’s “Deadline: White House." Monday featured fast-paced, immersive educational sessions topics on like prior authorization and appropriate use criteria; next steps in the Quality Payment Program initiated by the Medicare and CHIP Reauthorization Act; tips for successful state-level grassroots action; and more. Additionally, ACC President Mary N. Walsh, MD, FACC, mapped out the foundation for the College’s advocacy strategy and provided an illuminating peek behind the ACC Advocacy curtain with a step-bystep description of the College’s process for crafting statements rooted in the ACC Health Policy Principles in response to legislative developments. Attendees also heard from Francis Collins, MD, PhD, director of the National Institutes of Health, on the future of government-funded research. On Tuesday, armed with talking points, conference attendees headed to Capitol Hill for more than 300 meetings with senators and representatives.The College was honored to award Rep. John Lewis (D-GA) and Rep. Lynn Jenkins (R-KS) with the 2017 President’s Award for Distinguished Service, in part for their leadership on cardiac rehabilitation legislation that is strongly supported by the ACC. ACC Chapter Executive Gwen Goldfarb and former ACC President John Harold, MD, MACC, both received Excellence in Advocacy Awards as well. Scan the QR code to read more about the conference from Health Affairs Committee Chair Thad Waites, MD, FACC. CMS Proposes Cancellation of Episode Payment Models, Cardiac Rehab Incentive Model The Centers for Medicare and Medicaid Services (CMS) last month issued a proposed rule canceling its episode payment models (EPMs) and the cardiac rehabilitation incentive model, which were slated to start on Jan. 1, 2018. The agency also made significant changes to its joint replacement payment model, reducing the number of mandatory geographic areas participating and allowing participation in the remaining areas to be voluntary. “Changing the scope of these models allows CMS to test and evaluate improvements in care processes that will improve quality, reduce costs, and ease burdens on hospitals,” said CMS Administrator Seema Verma. “Stakeholders have asked for more input on the design of these models. These changes make this possible and give CMS maximum flexibility to test other episode-based models that will bring about innovation and provide better care for Medicare beneficiaries.” CMS had selected 1,120 hospitals to participate in the EPMs for acute myocardial infarction (AMI) (triggered by admissions for AMI and admissions representing percutaneous coronary intervention treatment for AMI) and coronary artery bypass for acute care hospitals. Additionally, 1,320 hospitals had been selected to participate in the Cardiac Rehabilitation Incentive Payment Model, which would have allowed for a retrospective payment based on total cardiac rehab use of beneficiaries attributable to participant hospitals. Cancellation of the program will impact eligible clinicians, including physicians and non-physician practitioners, who were planning to use participation in the EPMs to qualify as participating in Advanced Alternative Payment Models (APMs) outlined under the Quality Payment Program, particularly in this first year. ACC Advocacy staff and leaders are reviewing the update now and more information on the impacts to cardiovascular clinicians and next steps will be posted to ACC.org and included in the Advocate. Moving forward, CMS notes plans to increase opportunities for providers to participate in voluntary initiatives rather than large mandatory episode payment model efforts. “The ACC will continue to work with CMS on opportunities for clinicians to participate meaningfully in Advanced APMs,” said ACC President Mary Norine Walsh, MD, FACC. “As we move from volume-based care to value-based care, the path forward is challenging and we must work together to find solutions.” ICD Registry a Model for Quality Improvement The ACC’s ICD Registry, one of the College’s 10 NCDR registries, “has been a model of professional transparency, accountability, and science in exchange for expanded payment for devices” since its creation as a means for hospitals to meet the Centers for Medicare and Medicaid Services (CMS) requirement that patients receiving ICDs for primary prevention be enrolled in either an approved clinical trial or in a national registry, write Frederick M. Masoudi, MD, FACC, and William J. Oetgen, MD, FACC, in a recent leadership page published in the Journal of the American College of Cardiology. To date, more than 1.7 million ICD implantations have been recorded in the ICD Registry, and more than 75 peer-reviewed scientific papers using ICD Registry data have been published. “These studies have advanced our understanding of device selection, care, and outcomes nationally, addressing key questions of the effectiveness, safety, equity, and efficiency of care,” note Masoudi and Oetgen. “These studies have exponentially increased the value of the ICD Registry data well beyond the specific issues outlined in the original CED; their validity has been substantially enhanced with the availability of a true national denominator of patients receiving this therapy.” With CMS re-evaluating the registry mandate, Masoudi and Oetgen stress that the benefits of the registry must be considered. “Given that the indications for ICD therapy will change with this update, patients, physicians and policymakers will need valid contemporary data to ensure the optimal use of these devices and to achieve better outcomes,” they write. Firmware Update for Certain Abbott Pacemakers The U.S. Food and Drug Administration (FDA) recently approved a firmware update for certain Abbott (previously St. Jude Medical) pacemakers to reduce the risk of patient harm due to cybersecurity vulnerabilities. Intended as a recall, the corrective action is recommended to protect patients from cybersecurity exploits and intrusions, some of which could affect how the device operates. While there are confirmed vulnerabilities, there are no known reports of cybersecurity-related harm to the 465,000 devices currently implanted in the U.S. The firmware update must be administered in person by a health care provider. Prophylactic removal of the affected devices is not recommended by the FDA or Abbott. Pacemakers manufactured after Aug. 28 will already have the update installed and do not require any further action. For additional information, contact Abbott’s hotline at 1-800-722-3774. To date, more than 1.7 million ICD implantations have been recorded in the ICD Registry, and more than 75 peer-reviewed scientific papers using ICD Registry data have been published.
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