AAFP Board Chair Mary Frank, M.D., of Mill Valley, Calif., expressed the Academy's ongoing concern with physician payment as it relates to what she called the "(un)sustainable growth rate," in a Dec. 23 letter to CMS. The correspondence offered the Academy's comments on CMS' final rule on the 2006 Medicare physician fee schedule.
"We would be remiss if we did not address CMS' comments relative to the SGR and update in the conversion factor for 2006," Frank wrote to CMS Administrator Mark McClellan, M.D., Ph.D.
"Absent Congressional action, as CMS notes, the conversion factor is projected to decrease about 27 percent from 2006 to 2012, while the Medicare Economic Index (a measure of inflation in physicians' costs) is projected to increase 19 percent over the same time period," said Frank. "We understand that the formula behind the SGR is statutory in nature, which is why we and every other national medical specialty society are actively lobbying Congress to make the necessary changes. However, there are things CMS could do to help but chooses not to for reasons we do not find defensible," she said.
CMS could immediately remove, retroactive to the inception of the SGR, physician-administered drugs from the SGR, said Frank. "We know, as CMS notes, that removing drugs retroactively from the SGR will not result in a positive update for 2006 or the succeeding few years. But, it will ameliorate the reduction and make a long-term, Congressional solution more affordable," said Frank. "We believe CMS should correct the problem, not continue to perpetuate it."
Frank also reiterated the Academy's concerns about CMS' proposal to link a portion of Medicare payments to what CMS calls "valid measures of quality and effective use of resources" through a voluntary reporting program. "We have shared our initial concerns about the voluntary reporting program with CMS staff in face-to-face meetings and through separate correspondence, and we want to emphasize our efforts to work with CMS to craft a workable program," said Frank.
"However, it is important that work on the voluntary reporting program neither distract nor detract from efforts to fundamentally solve the SGR problem, because allowing the payment rate to fall below what is was five years ago will neither encourage nor reward efficient and high-quality care," she said.
Frank commented on other items in the 2006 fee schedule, including
- CMS' decision to withdraw its practice expense methodology proposal due to inaccurate published data,
- its decision to adopt a phase-in policy for multiple-procedure payment reduction for diagnostic imaging, and
- its intention to "carrier-price" new codes for moderate sedation services.
The letter asks CMS to reconsider its decision regarding sedation codes, noting that the Relative Value Update Committee carefully vetted information provided to it before assigning what the AAFP feels are accurate values to the six CPT codes (99143, 99144, 99145, 99148, 99149 and 99150) involved.
