Much of the focus of the College’s health policy
and advocacy efforts has been on monitoring and
assisting CMS’ implementation of MACRA.
informed CMS that this proposal is so burdensome that
few physicians will be able to comply by January 1, 2017,
and that the data CMS collects likely will be inaccurate and unusable. The ACS has urged CMS to proceed
slowly, first developing a sound survey methodology. If
CMS intends to move forward with claims-based data
collection, we urge the agency to use Current Procedural Terminology (CPT) code 99024. If collecting
accurate data is infeasible by January 2017, the College
supports spending more time on further development
of this policy with input from specialty societies.
On August 25, Linda Barney, MD, FACS, Vice-Chair, GSCRC, and Eric Whitacre, MD, FACS, a
member of that committee, testified at a CMS listening session regarding the agency’s plan to collect data
on medical visits associated with 10- and 90-day global
codes. In addition, the ACS submitted comments September 6 in opposition to CMS’ approach to global
codes data collection.
The proposed rule also provides values for new
moderate sedation codes. CMS said it appeared that
practice patterns for certain endoscopic procedures
were changing and that anesthesia was increasingly
being reported for these procedures even though
reimbursement for these services was automatically
included in payment to the physician furnishing the
primary services. As a result, the agency proposes separate codes for moderate sedation.
In addition, the proposed rule updates the Medicare
Shared Savings Program, which facilitates coordination and cooperation among providers. Providers and
hospitals may participate in the Shared Savings Program by creating or participating in an Accountable
Care Organization (ACO). CMS proposes revisions to
ACO quality reporting measures that support alignment with the QPP.
Other provisions in the proposed rule pertain to
implementation of the Protecting Access to Medi-
care Act and direct CMS to establish a program to
promote appropriate-use criteria (AUC) for advanced
diagnostic imaging services. The ACS recommends
that CMS give providers more time before they are
required to consult AUC to make clinical decisions
so that the AUC program does not roll out simulta-
neously with the QPP.
The DAHP is continuing its efforts to draft a white
paper on graduate medical education (GME) reform. This
report is anticipated to be released early in the 115th
Congress and to be the starting point for congressional
efforts to examine the issue and propose legislation.
The College’s white paper addresses workforce, finance,
governance, and accountability issues.
To address the growing surgeon workforce short-
age, Reps. Larry Bucshon, MD, FACS (R-IN), and Ami
Bera, MD (D-CA), introduced H.R. 4959, the Ensuring
Access to General Surgery Act of 2016. This legislation
would direct the Secretary of the Department of Health
and Human Services (HHS) to study the designation
of a general surgery Health Professional Shortage Area
(HPSA) using criteria that the Health Resources and
Services Administration (HRSA) has developed to
determine whether certain geographic areas (urban,
suburban, or rural), population groups, or facilities are
experiencing health professional shortages. HRSA has
never designated an HPSA purely because of a short-
age of surgeons.
The ACS continues to monitor congressional
activity on Direct GME (DGME) and indirect medical education (IME) funding. House Ways and Means
Committee Chairman Kevin Brady (R-TX) introduced
the Medicare IME Pool Act of 2015, H.R. 3292, which
instructs the Secretary of the HHS to reimburse IME
funds to teaching hospitals in a lump sum, rather than
through the current add-on payment these institutions
receive per inpatient discharge. This lump sum change
would occur for cost-reporting periods ending during
or after fiscal year (FY) 2019. These lump-sum IME
payments would be made to teaching hospitals in the
same timeframe, approximately every two weeks, as
the DGME payments.
The bill also would require that the HHS Secretary
create a new IME pool, initially funded at $9.5 billion
in FY 2019. If new teaching programs are added to
the Medicare program, the Secretary must increase