Earlier this month, the AANS and CNS submitted several comment letters to the Centers for Medicare and Medicaid Services (CMS) regarding a number of issues contained in the proposed 2014 Medicare physician fee schedule and hospital outpatient department rules, which affect neurosurgeons and their patients.
Of particular concern to neurosurgeons, are the proposals related to Medicare’s quality programs, including the Physician Quality Reporting System (PQRS) and the new Quality Clinical Data Registry program, the Electronic Health Record (EHR) Incentive program, and the Physician Compare tool on the Medicare.gov website. As such, the AANS and CNS sent the following four letters to CMS, commenting on the shortcomings of these proposed rules.
- Physician Fee Schedule: Quality Clinical Data Registry Provisions
- Physician Fee Schedule: Quality-Related Provisions
- Physician Fee Schedule: Reimbursement Provisions
- Hospital Outpatient Prospective Payment System
In our letters, the AANS and CNS raised the following key points:
- Based on the requirements published in the proposed 2014 Medicare Physician Fee Schedule Rule, it appears that CMS fundamentally misunderstands the function of clinical data registries, and the power they have for moving the needle and making real progress on quality reporting within the PQRS program, and beyond. The new Qualified Clinical Data Registry (QCDR) proposal does not adhere to the statutory requirements set forth in the American Taxpayer Relief Act; rather it maintains the status quo by merely taking the current PQRS program and folding it into the new QCDR program. As a result, the proposed registry program fails to capitalize on the value of registries across Medicare’s quality programs and does not make physician quality measurement reporting more relevant and meaningful to clinicians and patients.
- Significant data inaccuracies remain in how physicians and group practices are listed and searchable within Physician Compare.
- Given the considerable concerns about the accuracy of the data and methodology used to set the new payment rates for stereotactic radiosurgery (a therapy used to treat brain cancer and other neurologic diseases), CMS should maintain the rates it proposed in the version of the Notice of Proposed Rulemaking published on July 19, 2013.
Throughout the rulemaking process, organized neurosurgery has been at the forefront of discussions on the best way to implement payment and quality reform measures and will continue to advocate aggressively on behalf of neurosurgeons in order to ensure their ability to provide timely, compassionate, high quality and state of the art treatment for patients in need of neurosurgical care.
