We Don’t Stop Advocating for You
Joseph Cody, MA, AAO-HNS Health Policy Analyst Udo Kaja, Program Manager, AAO-HNS Health Policy The passage of the Affordable Care Act (ACA) in the spring of 2010 was the most substantial overhaul of the healthcare system in 50 years, and the AAO-HNS Health Policy team, including staff and members of the Physician Payment Policy (3P) work group, have been hard at work tracking its implementation and actively advocating for otolaryngology—head and neck surgery throughout the process. These efforts have included providing input to government agencies charged with putting regulations into place and working with other medical associations on ACA implementation. At the end of August 2011, the Academy provided comprehensive feedback to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2012 Medicare Physician Fee Schedule (PFS). In the letter, we addressed the evaluation of potentially misvalued codes, quality reporting initiatives, and many other important areas that impact otolaryngology—head and neck surgery. We also commented on the Physician Feedback Program and Value Based Payment Modifier included in the rule, expressing concerns about the plans for evaluating the reports and the inclusion of appropriate risk adjustment. Earlier in the year, the Academy sent a comment letter to CMS providing input on the Accountable Care Organizations (ACO) proposed rule. In the letter, we highlighted the importance of specialists in promoting care coordination and stressed that the current ACO model proposed by CMS would be very challenging to implement. We encouraged CMS to adopt surgical measures specific to otolaryngology and also recommended that CMS provide a payment option that includes shared savings only without mandatory shared-loss provision. In November 2010, we sent a letter to CMS urging them to implement retroactive payment increases for physicians stemming from provisions in the ACA. In October 2010, the Academy was part of a coalition that sent a letter urging members of the Labor-HHS-Education Subcommittee on Appropriations to fully fund a provision in the Affordable Care Act that would establish a loan repayment program for pediatric medical specialists training in underserved areas across the U.S., potentially increasing the pediatric subspecialty workforce and improving access-to-care issues for their services. Efforts are still under way to fund this important provision. Along with implementation of healthcare reform, we also were active in implementation of the American Recovery & Reinvestment Act (ARRA). Efforts included the Academy offering feedback on the Office of the National Coordinator for Health Information Technology (HIT) Policy Committee’s proposed meaningful use Stage 2 criteria. In our letter, we urged the HIT Policy Committee to allow for greater flexibility in the requirements to increase physicians’ adoption rates for EHRs. We thank the Medical Informatics Committee for reviewing the proposed criteria and for its work in drafting the letter. On September 13, 2010, in conjunction with the AMA and some specialty associations, we sent a comment letter to the Department of Human and Health Services (HHS) regarding its proposed changes to the Health Insurance Portability and Accountability Act (HIPAA). In the letter, we recommended that HHS pursue privacy and security safeguards that are practical, flexible, and affordable for physicians, suggested that they work to identify any state laws that conflict with the proposed changes, requested that they postpone the compliance deadline from 180 days after the effective date of the final rule until one year, and much more. The Health Policy team has also been actively involved in other regulatory implementations, including joining the efforts of the AMA and other specialty societies in December 2010 by supporting two separate letters to HHS Secretary Kathleen Sebelius recommending that HHS ask CMS to revise its condition to use e-prescribing activity during the first six months of 2011 as the basis for imposing penalties on physicians (in 2012 and 2013) in the Medicare E-prescribing program. As a result, CMS, on August 31, 2011, issued a final rule, which if finalized will add new exemption categories to enable physicians to avoid the 1-percent Medicare E-Rx penalty in 2012. In November 2010, we sent a letter to the Agency for Healthcare Research and Quality (AHRQ) regarding its draft Comparative Effectiveness Review (CER) of the diagnosis and treatment of Obstructive Sleep Apnea (OSA) in Adults. In the letter, we asked AHRQ to include (in their final review) that surgery was comparably effective if not better than Continuous Positive Airway Pressure (CPAP) to treat OSA. We thank the Sleep Disorders Committee for reviewing the proposed criteria and for its work in drafting the letter. The Academy will continue to monitor the implementation of the Affordable Care Act and other regulations that affect otolaryngology—head and neck surgery. You can check for regular updates to see what the Academy has been actively advocating for at the “What’s New” page located at www.entnet.org/Practice/CMS-News.cfm.
The passage of the Affordable Care Act (ACA) in the spring of 2010 was the most substantial overhaul of the healthcare system in 50 years, and the AAO-HNS Health Policy team, including staff and members of the Physician Payment Policy (3P) work group, have been hard at work tracking its implementation and actively advocating for otolaryngology—head and neck surgery throughout the process. These efforts have included providing input to government agencies charged with putting regulations into place and working with other medical associations on ACA implementation.
At the end of August 2011, the Academy provided comprehensive feedback to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the CY 2012 Medicare Physician Fee Schedule (PFS). In the letter, we addressed the evaluation of potentially misvalued codes, quality reporting initiatives, and many other important areas that impact otolaryngology—head and neck surgery. We also commented on the Physician Feedback Program and Value Based Payment Modifier included in the rule, expressing concerns about the plans for evaluating the reports and the inclusion of appropriate risk adjustment.
Earlier in the year, the Academy sent a comment letter to CMS providing input on the Accountable Care Organizations (ACO) proposed rule. In the letter, we highlighted the importance of specialists in promoting care coordination and stressed that the current ACO model proposed by CMS would be very challenging to implement. We encouraged CMS to adopt surgical measures specific to otolaryngology and also recommended that CMS provide a payment option that includes shared savings only without mandatory shared-loss provision.
In November 2010, we sent a letter to CMS urging them to implement retroactive payment increases for physicians stemming from provisions in the ACA. In October 2010, the Academy was part of a coalition that sent a letter urging members of the Labor-HHS-Education Subcommittee on Appropriations to fully fund a provision in the Affordable Care Act that would establish a loan repayment program for pediatric medical specialists training in underserved areas across the U.S., potentially increasing the pediatric subspecialty workforce and improving access-to-care issues for their services. Efforts are still under way to fund this important provision.
Along with implementation of healthcare reform, we also were active in implementation of the American Recovery & Reinvestment Act (ARRA). Efforts included the Academy offering feedback on the Office of the National Coordinator for Health Information Technology (HIT) Policy Committee’s proposed meaningful use Stage 2 criteria. In our letter, we urged the HIT Policy Committee to allow for greater flexibility in the requirements to increase physicians’ adoption rates for EHRs. We thank the Medical Informatics Committee for reviewing the proposed criteria and for its work in drafting the letter. On September 13, 2010, in conjunction with the AMA and some specialty associations, we sent a comment letter to the Department of Human and Health Services (HHS) regarding its proposed changes to the Health Insurance Portability and Accountability Act (HIPAA). In the letter, we recommended that HHS pursue privacy and security safeguards that are practical, flexible, and affordable for physicians, suggested that they work to identify any state laws that conflict with the proposed changes, requested that they postpone the compliance deadline from 180 days after the effective date of the final rule until one year, and much more.
The Health Policy team has also been actively involved in other regulatory implementations, including joining the efforts of the AMA and other specialty societies in December 2010 by supporting two separate letters to HHS Secretary Kathleen Sebelius recommending that HHS ask CMS to revise its condition to use e-prescribing activity during the first six months of 2011 as the basis for imposing penalties on physicians (in 2012 and 2013) in the Medicare E-prescribing program. As a result, CMS, on August 31, 2011, issued a final rule, which if finalized will add new exemption categories to enable physicians to avoid the 1-percent Medicare E-Rx penalty in 2012.
In November 2010, we sent a letter to the Agency for Healthcare Research and Quality (AHRQ) regarding its draft Comparative Effectiveness Review (CER) of the diagnosis and treatment of Obstructive Sleep Apnea (OSA) in Adults. In the letter, we asked AHRQ to include (in their final review) that surgery was comparably effective if not better than Continuous Positive Airway Pressure (CPAP) to treat OSA. We thank the Sleep Disorders Committee for reviewing the proposed criteria and for its work in drafting the letter.
The Academy will continue to monitor the implementation of the Affordable Care Act and other regulations that affect otolaryngology—head and neck surgery. You can check for regular updates to see what the Academy has been actively advocating for at the “What’s New” page located at www.entnet.org/Practice/CMS-News.cfm.