If you have family or friends working in private practice or a business that depends on private practice, contact congress and CMS.
If you are a Tricare beneficiary, consider the effects of this rule.
Dont forget...Commercial Insurance is tied to Medicare.
The overall plan is clear. CMS is attacking outpatient practitioners to force them into big hospital managed care.
The government will cut costs by limiting access.
Think about how reduced access will affect people with limited ability to drive.
Think about how decreased access will affect health care shortage areas.
Hospitals charge 5-9 times Medicare. Will it save you money? Absolutely not. You have less access and higher charges.
JR
Full article here
Federal register with link to comments here
Wednesday, August 07, 2013
New Proposed Cuts in EEG Reimbursement Imperil Epilepsy Care
BY ORLY AVITZUR, MD
Right on the heels of devastating nerve conduction study (NCS) cuts which crippled many neurology practices this year, the Centers for Medicare and Medicaid Services (CMS) has now released a proposed rule that would substantially reduce payments for electroencephalography (EEG) performed in the office. The proposed Medicare Physician Fee Schedule for 2014, announced on July 8 — http://go.cms.gov/12TOqIS — listed 200 services — including eight EEG codes — that would be affected by a cap to reduce non-facility practice expense values so that payment does not exceed the hospital outpatient payment rate, which uses the ambulatory payment classification system. The measure cuts physician office payment by about 50 percent for physicians who bill globally in the office — both technical and professional components.
THE FIGURES LOOK GRIM
One of the biggest drops in payment will be for the most common EEG code — CPT code 95819 for EEG awake and asleep. Using the current 2013 Medicare Fee Schedule, this procedure pays $421.34 for the technical payment in an office billing globally compared with the APC payment of $172.61 for provider-based billing that is used by hospitals. The payment for the physician's interpretation is the same regardless of which way the technical payment is billed: $56.14.
“For most physician practices, not just neurologists, the technical payments for procedures have historically been adequate and served as the profit centers for the practice, underwriting the payments for patient care, which are break-even at best but are typically the loss leader in the business of running a medical office,” said Gregory L. Barkley, MD, clinical vice chair in the department of neurology at Henry Ford Hospital in Detroit. The proposed drop in payment will put a substantial dent in the economics of running a neurology practice, he added.
Moreover, the EEG test is not always predictable. “The current rates cover a two-hour test that could easily stretch to three hours given that patients are often disabled, have seizures during the test, are sometimes uncooperative due to their altered mental status, and may need sedation or time to fall asleep in the middle of the day,” said Marc R. Nuwer, MD, PhD, department head of clinical neurophysiology at the Ronald Reagan University of California, Los Angeles Medical Center and former chair of the AAN Medical Economics and Management (MEM) Committee.
“Reimbursement to provide the EEG test now will be less than it was in the year 2000," he continued, “yet, the costs for the technologist, equipment, and supplies continue to rise with inflation, as do the costs of office rent, staff, and other expenses of keeping the doors open.”
“If the practice has bought an EEG machine, those costs are still there, as is the office overhead. If a part-time tech is brought in, can the margin be sufficient to keep the trained tech?” Dr. Barkley asked. He said the proposed rule raises these questions, as well: Can the EEG machine be sold and the EEGs be performed at the hospital with the physician still getting the professional payment without the technical expenses? If this path is taken, how does this affect the office overhead for everything else in the practice? This might trigger a move to a smaller, less expensive office. Alternatively, is there some other revenue stream that can be generated to replace this lost revenue?
“These are the decisions that any small business makes when the paradigm shifts. For some neurologists, this may be the last straw that triggers a decision to sell the practice and become an employed physician or even to retire,” he said.
CMS is accepting comments until Sept. 6 and will publish the final rule by Nov.1, which will go into effect on Jan. 1, 2014. In the meantime, the AAN has been refining its response, enlisting the help of its members, consultants, other professional societies, and consumer groups.
“The AAN has retained a powerful Washington, DC-based consulting group to help us take the most effective action,” said AAN President Timothy A. Pedley, MD, former chair of the department of neurology at Columbia University Medical Center. “We also immediately reached out to partner societies and patient groups to develop a united response to this proposal.”
Dr. Pedley noted that private practice neurologists are still reeling from the recent EMG/NCS cuts, adding that AAN members should start preparing for these potential EEG cuts. “They may decide they can no longer perform the tests in their office,” he said, emphasizing, “There is little margin left for those in neurology private practices.”
See the Sept. 5 issue of Neurology Today for more in-depth coverage on the proposed EEG cuts. For more on the issue of reimbursement cuts, seehttp://bit.ly/1bbOsyh andhttps://www.aan.com/public-policy.
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