SCAI Responds to CMS Regarding Proposed AMI Bundles
October 3, 2016—The Society for Cardiovascular Angiography and Interventions (SCAI) announced it has recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rulemaking for bundled payment models for high-quality, coordinated cardiac care.
In a letter to CMS Acting Administrator Andrew M. Slavitt, SCAI President Kenneth Rosenfield, MD, stated that the society supports CMS’s proposal to have coronary artery bypass graft (CABG) procedures placed in a separate CABG-only bundle, but it is concerned that the novel financial incentives in these bundles could result in unintended consequences. The SCAI letter is available online here.
Released on July 25 and available online here, the CMS Fact Sheet outlines three new significant policies in the proposal: (1) new bundled payment models for cardiac care, as well as an extension of the existing bundled payment model for hip replacements to other hip surgeries; (2) a new model to increase cardiac rehabilitation utilization; and (3) a proposed pathway for physicians with significant participation in bundled payment models to qualify for payment incentives under the proposed Quality Payment Program. The complete document is available online in the Federal Register here.
Although pleased that the document proposes a quality measure requiring facilities to submit clinical data for procedures, SCAI said it is disappointed that CMS will not be using more clinical data to assess the reasons for poor patient outcomes.
Additionally, the SCAI letter suggests that this bundling effort might discourage the recommended course of care for acute myocardial infarction patients with multivessel disease, who often should get a secondary percutaneous coronary intervention (PCI) procedure.
In the proposed physician payment rule for 2017, CMS proposes to unbundle the primary PCI payments from the incorporated moderate sedation and force physicians to bill for this separately. The SCAI letter stated, “We oppose this proposal for a variety of reasons, but in relation to this project where CMS is bundling payments for PCI treatments we suggest that the introduction of a new physician billing system for PCI may complicate CMS’s analysis of the demonstration program. We recommend that CMS not unbundle this service, doing so just complicates billing and data.”