The United States Congress and federal regulatory agencies, such as the Centers for Medicare and Medicaid Services (CMS) and the Agency for Healthcare Research and Quality, make many critical decisions on issues that have an impact on vascular surgeons and their patients. The Society for Vascular Society® (SVS) Health Policy Committee monitors these issues and oversees SVS lobbying efforts to ensure the interests of the vascular surgery specialty are represented in critical legislative and regulatory decisions.
MACRA, signed into law in April 2015, replaced the Sustainable Growth Rate formula for updates to the Medicare physician fee schedule.
Phasing in to a new system will occur from 2015-2019, with a .5 percent base update in years 2016-19 (a separate .5 percent increase went into effect in July 2015).
On Jan. 1, 2019, new payment models begin:
- Merit-Based Incentive Payment System (MIPS)
- Alternative Payment Models (APMS)
MACRA likely will have a greater influence on medical practice than any other recent law. SVS, along with other specialty societies, will be a key player in Washington policy-making around the law’s implementation. SVS also will be exploring ways to educate and support its members during the transition.
In November 2015, SVS submitted comments to the Centers for Medicare & Medicaid Services about MACRA. The comments concerned implementation of MIPS, MAPS, Promotion of Alternative Payment Models and Incentive Payments for Participation in Eligible Alternative Payment Models. The comments are at the link below.
Comments to CMS, Nov. 17, 2015 (.pdf)
On July 22, 2015, the Centers for Medicare and Medicaid Services (CMS) convened a panel of the Medicare Evidence Development and Coverage Advisory Committee (MEDCAC) on lower extremity peripheral artery disease (PAD).
The purpose of MEDCAC is to examine scientific evidence of existing interventions that aim to improve health outcomes in the Medicare population and address areas where evidence gaps exist. MEDCAC does not make coverage determinations, but the panel’s advice could determine the basis for future determinations by CMS on Medicare coverage of PAD.
The panel focused on three categories along the disease progression continuum: asymptomatic, intermittent claudication and critical limb ischemia. Clinical outcomes of interest relating to PAD include: reduction in pain, avoidance of amputation, improvement of quality of life and/or functional capacity including walking distance, wound healing, avoidance of cardiovascular events and avoidance of harms from interventions.
Two speakers who were invited to present at the MEDCAC meeting were SVS members Jack Cronenwett, MD who spoke on the Vascular Quality Initiative (VQI)/Using Registries to Provide Clinical Evidence and Matthew Menard, MD who spoke on the Best Endovascular vs. Best Surgical Therapy in Patients with Critical Limb Ischemia, known as the BEST-CLI Trial.
Also, three SVS members were chosen to present public comments: President-Elect Ron Fairman, MD; Michael Conte, MD; and Joseph Mills, MD. Dr. Fairman provided background on SVS, vascular surgery and the VQI; Dr. Conte discussed the 2015 SVS Clinical Practice Guideline on PAD, which addresses evaluation and management of asymptomatic PAD and intermittent claudication and Dr. Mills focused on critical limb ischemia and the SVS Lower Extremity Threatened Limb Classification System: Risk Stratification based on Wound, Ischemia and Foot Infection (WIFI).
Following are their slides:
MEDCAC Fairman, Mills Conte - 2015.ppt MEDCAC C_Menard.pdf
MEDCAC Cronenwett VQI 6-23-15 final.pptx
The Screening Abdominal Aortic Aneurysms Very Efficiently Act (SAAAVE) became effective on January 1, 2007. It provides a one-time AAA ultrasound screening for at-risk Medicare beneficiaries as part of the Welcome to Medicare Physical Exam. Because of barriers to this screening, such as a required referral, fewer than 10,000 beneficiaries were screened for AAA in 2007. Through the health care reform process, SVS lobbied to increase the number of Medicare beneficiaries who take advantage of this benefit. As a result, the Disease Prevention section of the health care reform law includes authorization for the US Department of Health and Human Services Secretary to modify coverage of existing preventive services if the changes are consistent with United States Preventive Services Task Force recommendations. In addition, co-pays were eliminated in Medicare for this screening.
SVS comments on proposed and final rules that have an impact on vascular surgeons and their patients. The rules are drafted by (US) federal agencies typically following the enactment of legislation and are posted in the Federal Register. SVS always comments on Medicare Physician Fee Schedule rules that are drafted by CMS.
Health Care Reform
The (US) House of Representatives passed the Senate health care reform bill and it was signed into law by US President Barack Obama on March 23, 2010. The House passed a “fixes” reconciliation bill on March 23, 2010. The Senate made some minor changes to the reconciliation bill and passed it on March 25, 2010. Because of the changes, the House had to again vote on the bill, which they passed on March 25, 2010 and the President signed that bill into law on March 30, 2010. Many of the provisions will not take effect until 2014. Despite being law, SVS will continue to advocate against provisions which are problematic, such as the unelected, unaccountable Independent Payment Advisory Board.
Communications sent to US leaders include:
Across-the-board cuts to imaging were included in the 2005 Deficit Reduction Act (DRA), which became effective on January 1, 2007. SVS was successful in removing five physiologic vascular lab codes from DRA and averting additional cuts in the health care reform law. SVS also supports accreditation for vascular labs and credentialing for vascular lab staff.
MedPAC’s June 2011 Recommendations to Congress on Imaging Create Concern
The Medicare Payment Advisory Commission's (MedPAC) Annual Report to Congress includes a recommendation that seeks to penalize physicians when they order tests for their patients and then perform and interpret them in their own offices. Other imaging recommendations include extension of the current across-the-board multiple procedure payment reduction to physician interpretation and mandatory prior authorization for advanced diagnostic services. SVS has signed onto a statement opposing these recommendations. Also, the complete MedPAC report can be accessed online. The good news is that MedPAC is no longer recommending the elimination of the Stark in-office ancillary services exception.
The Sustainable Growth Rate (SGR) formula continues to be used for Medicare physician payment. Even though Medicare pay cuts for physician services have been averted for the last seven years with small increases or freezes, SVS supports legislation that would repeal the SGR and create a permanent solution for payment. This issue was not addressed in health care reform.
Updated January 2014SVS_Comments_MIPS_APMs_RFI11-15.pdf