Physician Payment Policy (3P) Workgroup Update
James C. Denneny III, MD Coordinator for Socioeconomic Affairs Jane T. Dillon, MD Coordinator for Practice Affairs and Co-chairs of 3P The Physician Payment Policy Workgroup (3P), co-chaired by James C. Denneny III, MD, and Jane T. Dillon, MD, is the senior advisory body to Academy leadership and staff on issues related to socioeconomic advocacy, regulatory activity, coding or reimbursement, and practice services or management. 3P and the Health Policy staff were busy in the last quarter of 2013 with a continued high level of activity, constant emails, and monthly calls, working diligently and tirelessly on behalf of all members. Key 3P Accomplishments Included: Face-to-Face Meeting with CMS/CMMI Representatives in November 2013 In early November, Academy leaders James C. Denneny, III, MD, Lisa E. Ishii, MD, MHS, (coordinator-elect for Research and Quality Improvement) and David Nielsen, MD, along with Health Policy and Research/Quality Improvement staff, Jean Brereton, MBA, senior director, Research, Quality and Health Policy, and Jenna Kappel, MPH, MA, director, Health Policy, met with Patrick Conway, MD, chief medical officer for Centers for Medicare & Medicaid Services and acting director for Center for Medicare & Medicaid Innovation (CMMI), along with other top officials at CMS to discuss payment reform efforts and the need for development of additional clinical quality measures to ensure successful participation in the PQRS and Value Based Modifier programs by otolaryngologists. The Academy representatives inquired as to why five of the nine sinusitis measures were not accepted within the 2014 proposed fee schedule, and outlined our continued concerns regarding CMS’ proposed Outpatient Prospective Payment System cap policy, which, if finalized in 2014, would reduce practice expense relative value units for 13 otolaryngology services when performed in the office setting. This meeting was yet another effort by the Academy to ensure CMS understands the critical role otolaryngologists play in the healthcare system and the influence these programs and policies have on our specialty. Direct Impact: Our meeting with Dr. Conway was instrumental in acceptance of four adult sinusitis measures for 2014 PQRS reporting. Continued dialogue also maintains the Academy’s high-level visibility with CMS. As a result of numerous advocacy efforts, including these face-to-face meetings, and comment letters, CMS decided not to move forward with the OPPS cap policy and finalized the four adult sinusitis measures for PQRS reporting in 2014. For more details on the Medicare Physician Fee Schedule final rule’s influence on otolaryngology, see page 31. Regulatory Issues: Academy Advocates on Behalf of Members Meaningful Use Stage 3 In November, the Academy submitted a comment letter to CMS regarding Proposed Clinical Quality Measures (CQMs) for Use in Stage 3 of the EHR Meaningful Use Incentive Program. Specifically, the proposed Stage 3 measure on Overuse of Diagnostic Imaging for Uncomplicated Headache. The letter also reiterated the Academy’s concerns regarding Stage 2 timing requirements and Stage 3 thresholds and penalties. Input was based on feedback from the Imaging Committee, PSQI, and 3P. Colorado Clean Claims Act The Academy has been active in providing comments to the Colorado Clean Claims Act Task Force, an effort to develop a standardized set of payment rules and claim edits to be used by payers and healthcare providers. This is being closely monitored as it could be used in many other parts of the nation. In the summer, we submitted a formal letter on the first round of rules released for comment. These comments were reviewed and vetted through the CPT team, Richard Waguespack, MD, Bradley F. Marple, MD, and Lawrence M. Simon, MD. During the second round of review, the task force liaison reached out to the Academy directly, seeking our input on a few of the rules, and we provided input on the multiple procedure payment rule and the modifier -50 draft rule. Finally, the task force liaison sent us an early preview of the third round proposed rule on multiple endoscopies, which the CPT team reviewed in October and submitted comment on. ICD-10 Also in November, the Academy submitted comments to the Centers for Disease Control and Prevention regarding the new ICD-10 Codes for Unilateral Hearing Loss in support of the Conductive and Sensorineural Hearing Loss proposal presented during the ICD-10-CM/PCS Coordination and Maintenance Committee Meeting on September 18, 2013. The comments oppose the removal of references of contra-laterality and instead state that the codes are unilateral and retain language referencing which ear the diagnosis relates to. This will facilitate the fact that different types of hearing loss conditions can exist in each ear. RUC and CPT Update The Academy is surveying new CPT code 4319X in preparation for the January 2014 AMA Relative Value Scale Update Committee (RUC) meeting. After only a week and a half, the Academy obtained an impressive 146 responses. The minimum requirement by AMA is 30 surveys so this response rate is excellent and is helpful to the Academy’s RUC team, who must base the recommendations for relative value units (RVUs) on the data received. The survey closed early December and was sent to our practicing members specializing in head and neck and laryngology/bronchoesophagology with the support/assistance of AHNS, ALA, and ABEA. Many thanks to the physician leadership of these subspecialties who made the large survey response possible. AMA CPT/RBVS Symposium At the AMA CPT/RBVS Symposium in Chicago, Dr. Waguespack presented on new, and modified, CPT codes for otolaryngology for 2014, including flexible and rigid transnasal esophagoscopy (otherwise known as TNE) and chemodenervation of the larynx for spasmodic dysphonia, which were RUC surveyed by the Academy. Jenna Minton, Esq, senior manager, Health Policy, also represented the Academy at this meeting. Academy Releases New CPT for ENT Coding Guidance You may have noticed that your 2014 CPT Code Books include several modifications and additions to CPT codes used to report otolaryngology services. To assist members in understanding these changes and achieving correct coding, the Academy has revised our CPT for ENT articles on CPT 69210 Removal Impacted Cerumen and CPT 64617 Chemodenervation of Larynx (formerly reported by CPT 64613). These articles can be found in our Coding Corner of the website at www.bit.ly/CPT4ENT. Academy Collaborates with UHC on Septoplasty Coverage Policy and Provides Feedback on Premier Designation Program In November, Academy physician leaders, Drs. James Denneny and Richard M. Rosenfeld, MD, MPH participated in a conference call with United Healthcare National Medical Director Richard Justman, MD, and other physician leaders at UHC, to discuss and provide feedback on United’s Premier Designation program. This program recognizes physicians who meet certain cost/quality parameters and highlights them with a “Premier” designation in the UHC physician networks. During the call, we were able to get confirmation from UHC leadership to work in partnership with otolaryngology to develop future models for reimbursement. The Academy has also been collaborating with UHC to provide comments regarding their Rhinoplasty, Septoplasty, Vestibular Stenosis policy and are working with them to address issues we’ve continued to hear from members related to receiving a septoplasty review that was approved prior to surgery, but denied coverage following surgery. UHC is working to correct these issues. Also, the Academy is providing UHC with recommendations about patient criteria for septoplasty for UHC to consider including in their coverage policy. New HP Team Member The Health Policy team welcomes Danielle Jarchow, Esq, to the staff as a health policy analyst. Danielle comes from a family of otolaryngology-head and neck surgeons with her father and sister, who practice in academic and private practice, members of the Academy. “HP Update” Archives Missed the last edition of the “HP Update”? Access the monthly newsletter: http://www.entnet.org/Practice/HP-Update.cfm. For questions on the above Health Policy issues, please send an email to HealthPolicy@entnet.org.
James C. Denneny III, MD
Coordinator for Socioeconomic Affairs
Jane T. Dillon, MD
Coordinator for Practice Affairs and Co-chairs of 3P
The Physician Payment Policy Workgroup (3P), co-chaired by James C. Denneny III, MD, and Jane T. Dillon, MD, is the senior advisory body to Academy leadership and staff on issues related to socioeconomic advocacy, regulatory activity, coding or reimbursement, and practice services or management. 3P and the Health Policy staff were busy in the last quarter of 2013 with a continued high level of activity, constant emails, and monthly calls, working diligently and tirelessly on behalf of all members.
Key 3P Accomplishments Included: Face-to-Face Meeting with CMS/CMMI Representatives in November 2013
In early November, Academy leaders James C. Denneny, III, MD, Lisa E. Ishii, MD, MHS, (coordinator-elect for Research and Quality Improvement) and David Nielsen, MD, along with Health Policy and Research/Quality Improvement staff, Jean Brereton, MBA, senior director, Research, Quality and Health Policy, and Jenna Kappel, MPH, MA, director, Health Policy, met with Patrick Conway, MD, chief medical officer for Centers for Medicare & Medicaid Services and acting director for Center for Medicare & Medicaid Innovation (CMMI), along with other top officials at CMS to discuss payment reform efforts and the need for development of additional clinical quality measures to ensure successful participation in the PQRS and Value Based Modifier programs by otolaryngologists. The Academy representatives inquired as to why five of the nine sinusitis measures were not accepted within the 2014 proposed fee schedule, and outlined our continued concerns regarding CMS’ proposed Outpatient Prospective Payment System cap policy, which, if finalized in 2014, would reduce practice expense relative value units for 13 otolaryngology services when performed in the office setting. This meeting was yet another effort by the Academy to ensure CMS understands the critical role otolaryngologists play in the healthcare system and the influence these programs and policies have on our specialty.
Direct Impact: Our meeting with Dr. Conway was instrumental in acceptance of four adult sinusitis measures for 2014 PQRS reporting. Continued dialogue also maintains the Academy’s high-level visibility with CMS. As a result of numerous advocacy efforts, including these face-to-face meetings, and comment letters, CMS decided not to move forward with the OPPS cap policy and finalized the four adult sinusitis measures for PQRS reporting in 2014. For more details on the Medicare Physician Fee Schedule final rule’s influence on otolaryngology, see page 31.
Regulatory Issues: Academy Advocates on Behalf of Members
Meaningful Use Stage 3
In November, the Academy submitted a comment letter to CMS regarding Proposed Clinical Quality Measures (CQMs) for Use in Stage 3 of the EHR Meaningful Use Incentive Program. Specifically, the proposed Stage 3 measure on Overuse of Diagnostic Imaging for Uncomplicated Headache. The letter also reiterated the Academy’s concerns regarding Stage 2 timing requirements and Stage 3 thresholds and penalties. Input was based on feedback from the Imaging Committee, PSQI, and 3P.
Colorado Clean Claims Act
The Academy has been active in providing comments to the Colorado Clean Claims Act Task Force, an effort to develop a standardized set of payment rules and claim edits to be used by payers and healthcare providers. This is being closely monitored as it could be used in many other parts of the nation. In the summer, we submitted a formal letter on the first round of rules released for comment. These comments were reviewed and vetted through the CPT team, Richard Waguespack, MD, Bradley F. Marple, MD, and Lawrence M. Simon, MD. During the second round of review, the task force liaison reached out to the Academy directly, seeking our input on a few of the rules, and we provided input on the multiple procedure payment rule and the modifier -50 draft rule. Finally, the task force liaison sent us an early preview of the third round proposed rule on multiple endoscopies, which the CPT team reviewed in October and submitted comment on.
ICD-10
Also in November, the Academy submitted comments to the Centers for Disease Control and Prevention regarding the new ICD-10 Codes for Unilateral Hearing Loss in support of the Conductive and Sensorineural Hearing Loss proposal presented during the ICD-10-CM/PCS Coordination and Maintenance Committee Meeting on September 18, 2013. The comments oppose the removal of references of contra-laterality and instead state that the codes are unilateral and retain language referencing which ear the diagnosis relates to. This will facilitate the fact that different types of hearing loss conditions can exist in each ear.
RUC and CPT Update
The Academy is surveying new CPT code 4319X in preparation for the January 2014 AMA Relative Value Scale Update Committee (RUC) meeting. After only a week and a half, the Academy obtained an impressive 146 responses. The minimum requirement by AMA is 30 surveys so this response rate is excellent and is helpful to the Academy’s RUC team, who must base the recommendations for relative value units (RVUs) on the data received. The survey closed early December and was sent to our practicing members specializing in head and neck and laryngology/bronchoesophagology with the support/assistance of AHNS, ALA, and ABEA. Many thanks to the physician leadership of these subspecialties who made the large survey response possible.
AMA CPT/RBVS Symposium At the AMA CPT/RBVS Symposium in Chicago, Dr. Waguespack presented on new, and modified, CPT codes for otolaryngology for 2014, including flexible and rigid transnasal esophagoscopy (otherwise known as TNE) and chemodenervation of the larynx for spasmodic dysphonia, which were RUC surveyed by the Academy. Jenna Minton, Esq, senior manager, Health Policy, also represented the Academy at this meeting.
Academy Releases New CPT for ENT Coding Guidance
You may have noticed that your 2014 CPT Code Books include several modifications and additions to CPT codes used to report otolaryngology services. To assist members in understanding these changes and achieving correct coding, the Academy has revised our CPT for ENT articles on CPT 69210 Removal Impacted Cerumen and CPT 64617 Chemodenervation of Larynx (formerly reported by CPT 64613). These articles can be found in our Coding Corner of the website at www.bit.ly/CPT4ENT.
Academy Collaborates with UHC on Septoplasty Coverage Policy and Provides Feedback on Premier Designation Program
In November, Academy physician leaders, Drs. James Denneny and Richard M. Rosenfeld, MD, MPH participated in a conference call with United Healthcare National Medical Director Richard Justman, MD, and other physician leaders at UHC, to discuss and provide feedback on United’s Premier Designation program. This program recognizes physicians who meet certain cost/quality parameters and highlights them with a “Premier” designation in the UHC physician networks. During the call, we were able to get confirmation from UHC leadership to work in partnership with otolaryngology to develop future models for reimbursement.
The Academy has also been collaborating with UHC to provide comments regarding their Rhinoplasty, Septoplasty, Vestibular Stenosis policy and are working with them to address issues we’ve continued to hear from members related to receiving a septoplasty review that was approved prior to surgery, but denied coverage following surgery. UHC is working to correct these issues. Also, the Academy is providing UHC with recommendations about patient criteria for septoplasty for UHC to consider including in their coverage policy.
New HP Team Member
The Health Policy team welcomes Danielle Jarchow, Esq, to the staff as a health policy analyst. Danielle comes from a family of otolaryngology-head and neck surgeons with her father and sister, who practice in academic and private practice, members of the Academy.
“HP Update” Archives
Missed the last edition of the “HP Update”? Access the monthly newsletter: http://www.entnet.org/Practice/HP-Update.cfm.
For questions on the above Health Policy issues, please send an email to HealthPolicy@entnet.org.