What would you like CMS to give you for Christmas? The AMA is showing its cards -- in
a recent letter sent to CMS chief Donald Berwick, the top physician advocacy group provided a long list of "the most burdensome regulations [physicians] deal with" and asked for change.
The letter is intended as a response to President Obama's Jan. 18 executive order asking federal agencies to remove or reduce regulations that unnecessarily have a negative impact on small business.
Obama used specific phrases to describe the regulations he had in mind: items such as "absurd and unecessary paperwork requirements" and unreasonable "burdens that have stifled innovation and have had a chilling effect on growth and jobs."
The AMA's response takes aim at a dozen Medicare and Medicaid regulations and policies, including a few recent favorites you'll recognize:
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Consult codes. Put simply, the AMA wants consults back. "As revealed in an earlier AMA survey conducted with 17 medical specialty societies, Medicare’s elimination of payment for consultations also had far greater consequences for many physicians than CMS projected," the AMA writes. "Specifically, although the agency predicted that no specialty would see Medicare revenues fall by more than 3%, nearly three-quarters of the 5,500 consultation survey respondents (72%) had seen decreases of more than 5%, and 30% had seen a decline of more than 15%. This disconnect creates questions as to whether CMS has met the President’s directive that 'each agency must … propose or adopt a regulation only upon a reasoned determination that its benefits justify its costs.'" To date, CMS has rejected our concerns as “hypothetical.” We submit that the views of 5,500 survey respondents should not be dismissed so lightly. Payment for consultations should be reinstated, CMS should work with the AMA and other physician groups to address problems with its new patient definition, and RAC and other audits of new patient visits should be suspended until this work is completed.
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Medicare enrollment process. The AMA is asking for CMS to simplify the enrollment process, citing the all-or-nothing consequences of making even a minor clerical error on CMS-855 forms. "Over the past few years, physicians have experienced tremendous problems with CMS’ enrollment program. These difficulties have led to serious cash flow disruptions for many practices. Some 12% of our administrative burden survey respondents found this to have been a problem and one physician told us it 'took me eight months to get a Medicare number. I still haven’t been paid and will have to take bankruptcy soon.' Enrollment has perennially been an area where CMS contractors have struggled to implement agency changes with limited resources and within artificially short deadlines."
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PQRS feedback reports. Remember that the Physician Quality Reporting Initiative (PQRI) is now know as the Physician Quality Reporting System (PQRS). You are supposed to receive feedback reports from CMS, in a timely fashion, on your performance in the program. The AMA wants improvement on both the timeliness and content of the reports. "The AMA is disappointed that CMS’ feedback program for 2011 is merely consistent with current practices, which are extremely problematic. Issuing feedback reports 7-10 months after the reporting period has ended is not timely. Physicians cannot improve their understanding of program criteria or participation in a timely manner when there is such significant lag time between participation and distribution of feedback reports. To be effective, reports must be distributed during the reporting period to allow physicians to assess their reporting and performance status, and if needed, revise their reporting practices to be a successful participant."
How likely is it that CMS will turn back the clock on consults, significantly improve Medicare enrollment and PQRS? I'll leave that up to readers to ponder. Better be a good practice this year...