September 30, 2020
SCAI Recommends Changes to CMS Proposed Rules and Payment Plans for 2021
September 30, 2020–The Society for Cardiovascular Angiography & Interventions (SCAI) announced it has recommended changes to the Centers for Medicare & Medicaid Services (CMS) proposed rule for hospital outpatient departments and ambulatory surgery centers in 2021. Additionally, SCAI advised it has submitted its objection to CMS on the proposal to reduce Medicare’s conversion factor by 10.6% in 2021.
In a letter to CMS Administrator Seema Verna on September 22, SCAI recommended that intravascular lithotripsy procedures (HCPCS code C9764) be added to the ambulatory patient group for level 3 endovascular procedures (APC 5193). This APC contains procedures that are similar both clinically and in resource costs, stated SCAI.
SCAI also recommended that ambulatory surgery centers be compensated for the additional costs of fractional flow reserve studies and intravascular ultrasound. SCAI noted that greater use of these technologies has been shown to prevent unnecessary procedures, improve patient outcomes, and decrease overall cost to the health care system.
In a separate letter to Administrator Verna on September 22, SCAI outlined its objection to CMS’s proposed reduction to the conversion factor.
According to SCAI, this is a key component of payment rates for all procedures. CMS is proposing the reduction to offset significant payment increases for evaluation and management (E&M) services. The net effect of these changes is estimated to be -3% for interventional cardiologists.
Under normal circumstances, CMS is required to make changes to the fee schedule revenue-neutral, but SCAI asserted that these are not normal times. SCAI recommends that CMS use emergency powers and/or new legislation to not reduce the conversion factor in 2021. SCAI is working to obtain legislation enacted to force CMS to change its plans.
Other recommendations that SCAI made were:
- SMS should remove the National Coverage Determination (NCD) for transvenous (catheter) pulmonary embolectomy (240.6), which bans coverage of these procedures. According to SCAI, the NCD is outdated and is causing confusion among physicians, hospitals, and patients. SCAI noted that the NCD is approximately 40 years old and has never been reconsidered. Additionally, the NCD does not provide any details about the procedure or devices and fails to cite any evidence supporting noncoverage.
- CMS should accept all the American Medical Association relative value committee’s (RUC) work value recommendations for new and revised CPT codes for 2021. SCAI objected to CMS’s plans to lower the work values for one of the three new atrial septostomy codes. CMS proposes to use the RUC survey’s 25th-percentile work relative value unit (RVU) of 8.00 instead of the 10.50 median work RVU recommended by the RUC. SCAI maintains that CMS did not recognize the significantly increased intensity and complexity of placing a stent within the beating heart with the risk of the stent embolizing from the intended location.
- CMS had asked for stakeholder input regarding payments for prothrombin/international normalized ratio services. SCAI stated it is not equipped to comment on some of the cost details but registered concern about adequate patient access because the payment declines of approximately 75% for these procedures may reduce patient access and result in unfortunate health outcomes.
In an announcement on August 5, SCAI advised its members that the CMS was proposing a shift in payments from procedures and to E&M services for 2021 and noted initiatives the society was taking to respond to this. SCAI provided a PDF of the complete 1,355-page document, “Medicare Program; CY 2021 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; et al” (CMS-1734-P), and a CMS Fact Sheet of the proposed policy, payment, and quality provisions changes is also available on the agency’s website.