A new timeline the Centers for Medicare & Medicaid Services (CMS) plans to implement for reviewing new, revised and potentially misvalued services could significantly slow the timeframe for implementing important CPT® code updates and changes to the values of physician services. The AMA and 70 medical associations sent a letter last month, calling on the agency to reconsider the proposal.
While the proposed revisions would provide additional transparency to the code valuation process, the new timeline simultaneously would stand in the way of more timely code and valuation updates needed to reflect changes in clinical care. The proposed timeline would extend the time required to generate a code or relative value from 14-22 months from the time of application to 22-30 months, the letter (AMA login required) said.
The new timeline calls for consideration of all code and relative value changes to shift from inclusion in the Medicare Physician Fee Schedule interim final rule to inclusion in the proposed rule, beginning with the 2016 rule. The letter calls for CMS instead to implement changes to the timeline and procedures in the 2017 CPT cycle and the 2017 Medicare Physician Fee Schedule.
The letter also called out CMS’ proposal to require all recommendations from the Relative Value Scale Update Committee (RUC) to be submitted by Jan. 15 of each year. The change would only allow a single opportunity for the medical community to offer recommended valuation of new technology and code bundles for 2016.
Meanwhile, for later years, the proposed changes would greatly delay the ongoing process of generating codes and relative values “at a time when CMS, the CPT Editorial Panel and the RUC are being asked to reduce the amount of time needed to accommodate changes,” the letter said.
Accepting the proposed work flow modifications would eliminate the need for CMS to create “G” codes, which are temporary codes that essentially duplicate CPT codes. The organizations said that G codes would add to physician practices’ administrative burdens because they would need to learn and implement new codes within a short time period, also increasing the risk for coding errors.
“We believe that the G code proposal is entirely unworkable and should not be considered in finalizing the new process,” the letter said.
CMS also proposed to eliminate the “refinement panel” process, now used to consider comments on interim relative values.
“For nearly two decades, the CMS refinement panel process was considered by stakeholders to be an appeals process,” the letter said. “The complete elimination of the refinement panel indicates that CMS will no longer seek the independent advice of contractor medical officers and practicing physicians and will solely rely on agency staff to determine if the comment is persuasive in modifying a proposed value.”
CMS’ final rule will be released Nov. 1.
