Summaries of CMS Regulations and the Academy's Comment Letters

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Comment Letters

Summaries of Regulations and their Impact on Otolaryngology - Head and Neck Surgery

Comment Letters

Academy’s Comment Letter on the Final Rule for CY 2012 Medicare Physician Fee Schedule
On January 2, 2012, we submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the final rule for the CY 2012 Medicare Physician Fee Schedule. In the letter, the Academy addressed the Sustainable Growth Rate (SGR) formula, potentially misvalued codes, quality reporting initiatives and other important issues that affect otolaryngology- head and neck surgery.

Academy's Comment Letter on the Proposed Rule for CY 2012 Medicare Physician Fee Schedule On August 30, 2011, we provided comprehensive feedback to CMS on the proposed rule for the CY 2012 Medicare Physician Fee Schedule (PFS). In the letter, we addressed the evaluation of potentially misvalued codes, quality reporting initiatives and many other important areas that impact otolaryngology – head and neck surgery.  

Academy’s Comment Letter on the Proposed Rule for CY 2011 Medicare Physician Fee Schedule
On August 23, 2010 we submitted a comment letter to CMS on the proposed rule for the CY 2011 Medicare Physician Fee Schedule. In the letter, we addressed the elimination of consultation codes, the sustainable growth rate, the resourced-based practice expense relative value units, potentially misvalued codes under the PFS and many other important areas.

Academy's Comment Letter on the Proposed Rule for CY 2010 Medicare Physician Fee Schedule (MPFS) On August 31, 2009 we submitted a comment letter to CMS on the proposed rule for the CY 2010 MPFS. In this letter, we urged CMS to separately reimburse for canalith repositioning, supported the CMS's use of data from the Physician Practice Information survey (PPIS) to compute the practice expense component, and addressed other important issues.

Summaries of Regulations and their Impact on Otolaryngology - Head and Neck Surgery

CY 2012 MPFS Final Rule
CMS released the final rule for the CY 2012 Medicare Physician Fee Schedule. In the final rule, CMS estimates a 27.4% reduction in Medicare payment compared to the CY 2011 MPFS due to the Sustainable Growth Rate (SGR) if Congress does not intervene. The Academy has repeatedly called for the replacement of the SGR. CMS also responded to some of the Academy's comments to CMS on the proposed rule. To note, CMS decided not to change the proposed lower values for thyroid/ parathyroid and submandibular gland excision codes, maintaining its position that physician outpatient work following a 23 hour stay is less intense than inpatient work. CMS believes the valuation of the codes that fall into the 23 hour stay category should not reflect physician work associated with inpatient services. Also, CMS decided to deduce the sinus ostial dilation (CPT 31295-31297) practice expense values of the sinus surgery balloon supply kits to 0.5 units per procedure on an interim basis for 2012. Health Policy staff produced this detailed summary for member and will submit comments to CMS of issue by the Jan. 3rd deadline.  

CMS Issues Proposed Rules to Address Unneccesary, Obsolete, or Excessively Burdensome Medicare and Medicaid Regulations To see a summary of provisions affecting Otolaryngology- Head and Neck Surgery, click here

Potential 1% Increase for Otolaryngology - Head and Neck Surgery in the CY 2012 MPFS Proposed Rule
The Academy’s Research, Quality Improvement & Health Policy staff have summarized the payment and quality aspects of the CY 2012 proposed rule for the MPFS pertinent to our specialty.  Based on this analysis, the specialty may see a 1% increase (not including the potential overall 29.5% cut) in CY 2012. The Academy will submit comments to CMS advocating for our members’ interests. 

CY 2011 MPFS Final Rule
We have summarized the impact of the final rule for the CY 2011 Medicare Physician Fee Schedule (MPFS) so that you are aware of important changes that will affect you as an otolaryngologist - head and neck surgeon.

CY 2011 MPFS Proposed Rule
To ensure that you are aware of the potential changes in the MPFS that might affect you and your practice for services you perform on or after January 1, 2011, the Health Policy department has drafted a summary of the proposed rule for CY 2011 and its impact on otolaryngology - head and neck surgery. The Academy sent a comment letter (see link above) to CMS addressing our position on the proposed rule.

Increases for Otolaryngology – Head and Neck Surgery MS-DRG Codes
According to the final rule for the FY 2011 inpatient prospective payment system (IPPS), there are some tangible increases for otolaryngology - Head and Neck Surgery Medicare Severity – Diagnosis Related Groups. We have extracted pertinent MS-DRGs for our specialty that you may view here.

CY 2010 MPFS Final Rule
The Health Policy department has summarized the 2010 MPFS final rule and its impact on otolaryngology.

Page Last Updated on November 1, 2011