Archives for November 2022

We surpassed our GivingTuesday goal of $30,000—thank you so much!

The ASE Foundation is ecstatic to share that we have already surpassed our $30,000 fundraising goal! Thank you to the 109 donors who have contributed a total of $32,457.94 as of this afternoon. Thank you for your support on GivingTuesday!

We may have reached our goal, but we are not done! The Foundation is still accepting donations towards its GivingTuesday fundraiser until December 3, so if you have not already done so—it is not too late to donate! Every donation brings us closer to our 2022 Annual Appeal goal of $225,000.

An investment in the ASE Foundation is a testament of support in the future of cardiovascular ultrasound. Wherever your heart lies in our field, ASEF is making a difference. Show us #YourPriority with a donation to the initiative that most aligns with your passion. If you would like to make a donation to support a 2023 Global Outreach Travel Grant in memory of Greg Tatum, MD, FASE, please indicate that your donation is in his memory on the donation form.

100% of your donation will go toward charitable projects in 2023. Thank you for showing us that supporting the future of cardiovascular ultrasound is #YourPriority. Together we will continue to make a world of difference!

ECHO VOL 11 | Issue 11


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Today is GivingTuesday—Help Us Raise $30,000!

Hello, and Happy GivingTuesday! The ASE Foundation is thrilled to participate in this global giving movement for the 10th year in a row. To mark the occasion, we set an ambitious fundraising goal of $30,000. Will you join the movement and help us reach our goal?

Follow this link to make your donation today. Your contribution to the ASE Foundation is an investment in the future of cardiovascular ultrasound and directly impacts the scope and success of our 2023 initiatives. No matter where your heart lies, the Foundation can support your passion and you can take pride in knowing that 100% of your donation goes back out into the field.

On this special day, we ask that you remember the ASE Foundation. Donations towards our $30,000 fundraising goal will be accepted through December 3. When you donate, let us know what inspired your contribution on social media. Remember to include #GivingTuesday and tag @ASE360.

November JASE-Enhancing Stress Echo

The November JASE includes, “Passive Leg Raise Stress Echocardiography in Severe Paradoxical Low-Flow, Low Gradient Aortic Stenosis,” from Drs. Buffle, Papadis, Boscolo Berto, Grani, Seiler, and de Marchi. Dr. de Marchi noted, “Stress echocardiography has been relying on dobutamine, also for patients with aortic stenosis. This study evaluates an increase in LV filling using passive leg raise in both, classical and paradoxical low-flow low-gradient aortic stenosis. It shows that adding leg raise to dobutamine increases the parameters we wish to stimulate in stress echocardiography.”

Two other clinical investigations also look at novel applications of stress echo. Additional clinical investigations explore optimum indexing of cardiac measurements, fetal echo prediction of postnatal obstruction in total anomalous pulmonary venous connection, cardiac function and pulmonary hemodynamics in infants with Down Syndrome, and echocardiographic imaging of myocardial scar, with an accompanying editorial, “Detecting Scar in Echocardiography: Has the Power Shifted?” from Drs. Appadurai and Thomas. A review article, which offers CME, explores tricuspid regurgitation related to cardiac implantable electronic devices. A group of robust brief research communication on validation of alternative left atrial indexation methods in obesity, development of a new technique for ultrasound imaging of the innominate vein and the venous angle, local arterial stiffness assessment, and assessment of diastolic energy loss in hypertensives versus controls and thought-provoking correspondence round out the issue.

The President’s Message from Stephen H. Little, MD, FASE, illustrates how ASE is making sure that it is preparing, planning, and prioritizing to be a leader in how Societies grapple with all of the digital data that is part of general society and of course, echocardiography. The continuing education and meeting calendar outlines a multitude of learning options near and far.

ASE Releases New EchoGuide App

FOR IMMEDIATE RELEASE

Contact: Angie Porter
919-297-7152
aporter@ASEcho.org

American Society of Echocardiography Releases New EchoGuide™ App
The mobile and web app provides quick access to common and challenging echocardiography measurements and values

(DURHAM, NC, Nov. 9, 2022)—The American Society of Echocardiography (ASE) announced today that it is launching a new interactive mobile and web application for healthcare professionals providing cardiac care. EchoGuide™ is a calculator and algorithm app based on key guidelines published by ASE.

The free app offers physicians and sonographers quick access to common and challenging echocardiography measurements and values. Tools and functionalities are organized by cardiac structure and include over 50 complex calculators, charts and algorithms that provide quantitative assessment.

“The ASE EchoGuide app is a fantastic tool for echocardiographers, sonographers, and fellows in training that brings the comprehensive ASE guidelines to their fingertips. This practical app includes key reference tables, calculators, and easy-to-use multi-parametric integrative algorithms to increase your confidence level when interpreting or performing echocardiographic studies,” says Enrique Garcia-Sayan, MD, FASE, University of Texas Health Center in Houston.

One unique feature available to users is the ability to select their favorite and most-used interactive tools for easy access. Popular topics include the left and right ventricle, left and right atrium, valves including aortic, mitral, tricuspid, pulmonic and prosthetic, and z-scores for aortic root, among many others.

EchoGuide™, sponsored by Abbott, was developed by technology consultancy and custom software development firm Digital Mettle Custom Software based in Raleigh, N.C. The app is intended for educational/informational use only, and is not intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease by aiding clinical decision-making. Learn more at ASEcho.org/EchoGuide.

About American Society of Echocardiography
The American Society of Echocardiography (ASE) is the Society for Cardiovascular Ultrasound Professionals™. ASE is the largest global organization for cardiovascular ultrasound imaging serving physicians, sonographers, nurses, veterinarians, and scientists and as such is the leader and advocate, setting practice standards and guidelines for the field. The Society is committed to advancing cardiovascular ultrasound to improve lives. For more information, visit the ASE website ASEcho.org or social media pages on Facebook, Twitter, LinkedIn, or Instagram.

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CMS PFS and HOPPS Final Rules

 

 

On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) released the CY 2023 Revisions to Payment Policies Under the Physician Fee Schedule (PFS) and Other Revisions to Medicare Part B [CMS-1770] Final Rule, which includes final policies related to Medicare physician payment and the Quality Payment Program (QPP).  In addition, CMS released the calendar year (CY) 2023 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Final Rule [CMS-1772-FC], finalizing payment rates and policy changes affecting Medicare services furnished in hospital outpatient and ambulatory surgical center (ASC) settings for CY 2023.

PFS Overview

Conversion Factor

The final 2023 Medicare conversion factor (CF) is $33.06, reduced from the 2022 final conversion factor of $34.61. The final rule establishes a 4.47% cut to physician payments under the 2023 fee schedule unless Congress can pass legislation that would offset or mitigate this reduction in payment.

Stakeholders, including ASE, have advocated for an improvement over the proposed rule’s 4.47% reduction to the CF, but the final rule’s methodology resulted in a slight decrease. The update is based on several factors: a statutory 0% update scheduled for the PFS in CY 20231 and a funding patch passed by Congress at the end of CY 2021 through the Protecting Medicare and American Farmers from Sequester Cuts Act. This bipartisan legislation partially mitigated a 3.75% cut to the CY 2022 CF and staved off other Medicare cuts, including a phased-in delay of the Medicare sequestration and pay-as-you-go cuts. The 3% payment patch was only in effect for 2023 and the Medicare sequestration relief was phased out starting April 1, 2022. The overall negative adjustment to the CF for 2023 is driven by the expiration of the 3% payment patch and a statutorily required budget neutrality adjustment due to other spending increases. Additionally, unless Congress acts to further delay additional anticipated cuts arising from pay-as-you-go federal budget requirements, Medicare payments could be cut by an additional 4%.

Physicians are concerned that full relief may not be possible given the significant cost of trying to offset an almost 4.5% cut and numerous competing interests facing Congress in an end-of-year legislative package. ASE will continue to work with a coalition of national and state medical societies in urging Congress to prevent these cuts before January 1, 2023. 

Practice Expense

Last year, CMS finalized a proposal to update prices for clinical labor through a four-year transition period that will be completed in 2025. Physician specialties with substantially higher average shares of direct costs attributable to clinical labor are anticipated to see increases in payment from the clinical labor pricing update, while those with lower average shares of direct costs attributable to labor are anticipated to see decreases in payment. During the four-year transition period, clinical labor rates will remain open for public comment.  Unfortunately, echocardiography related services did see an increase in the clinical labor RVUs based on the revised calculations.

Although CMS did not propose a methodology for updating future PEs, CMS believes “it is necessary to establish a roadmap toward more routine PE updates.” CMS also opined that indirect PEs would benefit from a data refresh, and signals “[its] intent to move to a standardized and routine approach” to valuing indirect PEs. Unfortunately, CMS notes that it received few direct responses to many of the specific prompts included in its recent request for information and feedback. Most commenters, including ASE, recommended CMS delay any changes to update the indirect PE survey inputs and urged CMS to wait for the American Medical Association (AMA) data collection effort prior to implementing any changes. The AMA indicated it has continued to work on updates and would likely be ready by early CY 2024 with refreshed data. CMS, however, acknowledges comments that refreshed survey data alone would not address all the competing concerns that CMS must account for when allocating indirect expenses, and that the agency may look to supplement or augment survey data with other verifiable, objective data sets in the future, including data sets that are already in the public domain.

Split / Shared Visits

CMS will delay until CY 2024 the split (or shared) E/M visits policy originally scheduled for implementation in CY 2023. For CY 2023 (as in CY 2022) the substantive portion of a visit may be met by any of the following elements:

  • history
  • performing a physical exam
  • making a medical decision
  • spending time (more than half of the total time spent by the practitioner who bills the visit).

Under this change, echocardiographers furnishing split/shared E/M visits will continue to have a choice of history, physical exam, medical decision making, or more than half of the total practitioner time spent to define the substantive portion, instead of using total time to determine the substantive portion, until CY 2024. The ASE and many other specialties pushed CMS not to implement its new definition of “substantive portion” as more than half of the total visit time and we will continue to advocate against implementation of this policy change.

Merit-based Incentive Payment System (MIPS)

CMS will maintain the CY 2023 MIPS performance threshold at 75 points (same as CY 2022). This impacts the CY 2025 payment year. Please note, CY 2022 is the final year for the “exceptional bonus” for high MIPS scores. While most cardiologists continue to meet the minimum MIPS reporting thresholds, failing to satisfactorily participate in MIPS for the CY 2023 performance year will result in a 9% payment cut in CY 2025.

MIPS Value Pathways (MVPs) are intended to connect activities and measures from the four MIPS performance categories that are relevant to a specialty, medical condition, or a particular population. For the CY 2023 performance period, CMS will add 5 new MVPs to the previously announced 7 MVPs in the program. CMS will also add measures to the existing 7 MVPs.

HOPPS Overview

For CY 2023, CMS applied a productivity-adjusted market basket increase of 3.8% under the Hospital Outpatient Prospective Payment System (HOPPS) and the Ambulatory Surgical Centers (ASC) Payment System. However, CMS applied several budget neutrality and other adjustments, including a significant 3.09 percentage point reduction to account for changes to its 340B drug purchasing policy. After accounting for these adjustments, the CY 2023 HOPPS conversion factor increases by 1.67% over the 2022 value. The ASC conversion factor will increase by 3.88%, a different and more favorable adjustment largely because it is not directly impacted by the 340B-specific budget neutrality adjustment. In continuation of its existing policy, hospitals and ASCs that fail to meet their respective quality reporting program requirements will be subject to a 2% reduction.

Based on the finalized policies, CMS estimates that total payments to HOPPS and ASC providers (including beneficiary cost-sharing and estimated changes in enrollment, utilization, and case-mix) for CY 2023 will be approximately $86.5 billion and $5.3 billion, respectively, for an increase of approximately $6.5 billion and $230 million, respectively, from CY 2022 program payments.

Supervision by Non-Physician Practitioners

CMS further extends supervision authority to non-physician practitioners for select diagnostic services.  In 2020, in response to the COVID-19 pandemic, CMS liberalized its regulations to allow certain non-physician practitioners (nurse practitioners, physician assistants, clinical nurse specialists and certified nurse midwives) to supervise the performance of diagnostic x-ray tests, diagnostic laboratory tests and other diagnostic tests paid under the PFS for the duration of the PHE to the extent they were authorized to do so under their scope of practice and applicable state law. In the CY 2021 PFS final rule, CMS further revised its regulations to make the previous revisions permanent and to add certified registered nurse anesthetists to the list of non-physician practitioners permitted to provide supervision of diagnostic tests to the extent authorized to do so under their scope of practice and applicable state law.

CMS has finalized its policy to further revise existing supervision requirements to make clear that nurse practitioners, clinical nurse specialists, physician assistants, certified registered nurse anesthetists and certified nurse midwives may provide general, direct, and personal supervision of outpatient diagnostic services to the extent that they are authorized to do so under their scope of practice and applicable state law.

To view the Final CY 2022 Payment Rates – MPFS and HOPD, please log in to the ASE Member Portal and visit the Advocacy Portal page.

For further information please see:

CMS Final Rules and Fact Sheets  

CY 2023 Physician Fee Schedule Final Rule
CY 2023 Physician Fee Schedule Final Rule Fact Sheet

CMS HOPPS/ASC Final Rules and Fact Sheets    

CY 2023 HOPPS/ASC Payment System Final Rule
CY 2023 HOPPS/ASC Payment System Final Rule Fact Sheet

Mark Your Calendar for GivingTuesday 2022

GivingTuesday is a global day of giving celebrated the Tuesday after Thanksgiving. This year, it falls on November 29, and we are asking you to mark your calendars from November 27 – December 3 to make a contribution to the ASE Foundation. ASEF will be participating for the 10th year in a row, and we need your help to reach our fundraising goal of $30,000 USD.

Karla Kurrelmeyer, MD, FASE, has already pledged her support of our GivingTuesday fundraiser. Will you join her in making an early pledge? Our generous donors have helped us surpass our goal every year except one. Mark your calendars now and plan to donate or better yet, join Dr. Kurrelmeyer by pledging a donation today! Any contribution, big or small, brings us one step closer to our goal.

Donations for GivingTuesday 2022 will be accepted on the ASE Foundation website from November 27 – December 3.

Contact the Foundation at Foundation@ASEcho.org with any questions or to make your pledge.

REGISTER NOW: Advanced Imaging Techniques: A Virtual Experience

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Register for the upcoming course, Advanced Imaging Techniques: A Virtual Experience! The course will take place on December 3-4 and focus on practical how-to techniques of advanced 3D and Strain imaging. Improved software packages have resulted in increasing clinical application of these techniques, with 3D and Strain included as part of the routine echocardiographic examination.

This course will be presented in two, roughly three-hour sessions on Saturday, December 3, and Sunday, December 4. Day one will focus on advanced strain imaging and day two will focus on advanced 3D imaging.

Registration costs $199 USD for ASE members and $250 for nonmembers. The deadline to register is Thursday, December 1, 2022, 11:59 PM ET.

The American Society of Echocardiography designates this live course for a maximum of AMA PRA Category 1 Credits. Physicians should claim only the credit commensurate with the extent of their participation in the activity.

ASE Congressional MACRA RFI

 

 

 

 

October 31, 2022

The Honorable Ami Bera, M.D.                                 The Honorable Larry Bucshon, M.D.
U.S. House of Representatives                                   U.S. House of Representatives

The Honorable Kim Schrier, M.D.                             The Honorable Michael C. Burgess, M.D.
U.S. House of Representatives                                   U.S. House of Representatives

The Honorable Earl Blumenauer                               The Honorable Brad R. Wenstrup, D.P.M.
U.S. House of Representatives                                   U.S. House of Representatives

The Honorable Bradley Scott Schneider                  The Honorable Mariannette Miller-Meeks, M.D.
U.S. House of Representatives                                   U.S. House of Representatives

Dear Members of Congress:

The American Society of Echocardiography (ASE) appreciates the opportunity to respond to your request for feedback on actions Congress could take to stabilize the Medicare physician payment system, including reforming the current payment structure so it supports a system that provides greater value to patients and to physicians. The ASE is the Society for Cardiovascular Ultrasound Professionals™️. ASE is the largest global organization for cardiovascular ultrasound imaging serving physicians, sonographers, nurses, veterinarians, and scientists and as such is the leader and advocate, setting practice standards and guidelines for the field. Since 1975, the Society has been committed to advancing cardiovascular ultrasound to improve lives.

The increasing cost to physician practices to provide care without adequate inflationary updates, along with the new threat of annual cuts to the Medicare physician payment conversion factor due to the restraints of budget neutrality, point to the need to re-evaluate the physician payment system, and, specifically, the Medicare Access and CHIP Reauthorization Act (MACRA). The COVID-19 pandemic also uncovered weaknesses in our nation’s healthcare infrastructure and payment systems that have led to significant healthcare consolidation further threatening patient care in many areas.

On behalf of its members and the patients they serve, ASE is grateful for your outreach to healthcare providers, advocacy organizations and others for feedback on the current state of MACRA and associated payment mechanisms and ideas for reform. ASE is pleased to provide its perspective on the following topics:

  • Medicare Physician Payment
  • Barriers to Timely Care for Medicare Beneficiaries
  • Medicare’s Quality Payment Program

Medicare Physician Payment

Inflationary Updates and Payment Adequacy

When MACRA was passed, it replaced the sustainable growth rate (SGR) formula and ended roughly 12 years of repeated congressional intervention to prevent Medicare physician payment cuts that were triggered by the SGR when overall physician costs exceeded target expenditures that were pegged to growth in the national economy.

In its place, MACRA was intended to create payment stability and provide incentives to physicians for performing efficiently while delivering high-quality care. MACRA statutorily set modest Medicare physician payment updates, starting at 0.5 in 2015 through 2019, and 0 percent for 2020 through 2025. For 2026 and beyond, it is 0.75 percent for eligible alternative payment model (APM) participants and 0.25 percent for all others.

Over a 12-year period, during which the SGR was in effect, annual payment increases to physicians averaged about 0.3 percent, while the cost of running a medical practice increased about 3 percent annually.[1] The fact is that physicians are still paying for nearly two decades of insufficient payment updates. Taking inflation in practice costs into account, Medicare physician payment plunged 20 percent from 2001 to 2021.

A fundamental and critical step that Congress can take to create payment stability is to provide, beginning in 2023, a positive annual physician payment update that reflects inflation in practice costs.  It is indisputable that consolidation — vertical, horizontal, and cross-market — results in increased costs to the healthcare system which outweigh any suggestion that consolidation can lead to better care coordination and efficiency. In Medicare, vertical consolidation has been met with calls for site-neutral payment policies that are often focused on driving rates to levels that are unsustainable and that contributed to physician practices selling out to hospitals/health systems in the first place. It is time Congress understand the impact of consolidation and the increasing number of physicians who are choosing to forego independent practice for hospital employment — payment inadequacy and instability and regulatory burden.

Because it will take time to secure a massive, badly needed overhaul of the Medicare physician payment system, immediate action is needed to stop harmful cuts that will take effect on January 1, 2023 and to ensure future payment stability. ASE urges Congress to take action before the end of this year to:

  • stop the scheduled 4.42 percent budget neutrality cut to 2023 Medicare physician fee schedule payments;
  • end the statutory annual freeze and provide a Medicare Economic Index update for 2023; and
  • waive the 4 percent PAYGO sequester triggered by passage of the American Rescue Plan Act.

Barriers to Timely Care for Medicare Beneficiaries

There are a number of contributors to physician burnout, but prior authorization is one of the biggest causes.  Medicare Advantage (MA) and other private insurance plans routinely subject diagnostic tests and procedures to cumbersome authorization processes that lead to substantial treatment and diagnosis delays.  Echocardiographers are not given rules or indications of how these authorizations will be adjudicated. Prior authorization protocols unnecessarily delay patient care and shift costs onto providers who are uncompensated for the administrative time and staff required for authorization and appeals.

Denials of prior authorization requests are raising concerns about beneficiary access to medically necessary care. A report from the Office of the Inspector General found, upon examination of a random sample of prior authorization denials by MA plans, that 13 percent met Medicare coverage rules and likely would have been approved for these beneficiaries under original Medicare.[2] It is time that MA plans be held to some level of accountability when medically necessary appropriate treatment is withheld or delayed.

With nearly half the Medicare eligible population enrolled in a MA plan, legislation is urgently needed to reduce the burden of prior authorization on physician practices, as well as to improve patient outcomes by preventing delays in care and minimizing the number of patients who forego diagnostics and treatment altogether when it is denied or subjected to a lengthy appeal.

ASE endorses the Improving Seniors’ Timely Access to Care Act (S. 3018 / H.R. 3173) as a way to increase transparency and streamline prior authorization in the MA program and protect timely access to care for Medicare patients and calls upon Congress to pass the legislation this year.

Medicare’s Quality Payment Program

A goal of MACRA was to improve care for Medicare patients by shifting the payment system from volume to value. MACRA set up the Merit-based Incentive Payment System (MIPS) as a pathway to alternative payment models (APMs). The law lowered payment updates over time for MIPS participants to incentivize their move to APMs. For most specialties, including echocardiography, MIPS is a path to nowhere because of a lack of specialty APMs. As a result, physician practices are investing in MIPS participation to avoid payment penalties, but participation requires significant practice resources with little return on those investments amidst questions about whether MIPS even accurately captures quality or is incentivizing improvements in care delivery.

A recent published study on the costs for physician practices to participate in MIPS found physicians, clinical staff, and administrative staff together spent 201.7 hours annually on MIPS-related activities at a per-physician, per-year cost of $12,811.[3]  According to a survey conducted by the Medical Group Management Association, 90 percent of physician practice respondents said positive payment adjustments did not cover the costs of time and resources spent preparing for and reporting under MIPS.[4]

MIPS Value Pathways

Recently, CMS has begun a programmatic shift from MIPS to MIPS Value Pathways (MVPs). The MVP concept is a CMS iteration of the “Accountable Clinician Episodes” (ACE) concept developed and put forth to CMS by the AMA and other medical societies, including the ASGE. The intent behind the ACE option was to award MIPS credit to clinicians who engage in performance activities that satisfy the requirements of multiple MIPS performance categories (“multi-category credit”). For example, if a clinician reported quality measures electronically via a Qualified Clinical Data Registry (QCDR) that interfaces with their EHR, the clinician would receive full credit for the Promoting Interoperability category. The ACE concept was also envisioned as a long-run performance-based model or as a stepping stone for clinicians between participation in separate, unrelated MIPS measures and participation in an APM or Advanced APM.

MVPs, as currently designed, mirror many of the flaws in MIPS. If CMS moves ahead with MVPs as currently structured, it will be impossible to convince physicians that MVPs are anything more than a rebranding of MIPS with little-to-no benefit to physician practices or their patients.

Participation Incentives

In addition to making MIPS participation more cohesive and, ideally, more meaningful, ASE asks Congress to re-examine the incentive structure for participation.

MACRA’s $500 million exceptional performance bonus expires with payment year 2024 (performance year 2022). Because of the budget neutral redistributive nature of MIPS, there is very little return on investment, and therefore incentive, for MIPS participation. Budget neutrality is the fundamental flaw of the entire MIPS program – it needs winners and losers. A physician or physician practice can fully engage and still lose. Ideally, financial incentives for participation in MIPS would help practices build the infrastructure to move to APMs when they become available.  ASE asks Congress to allocate additional funds to extend the exceptional performance bonus beyond the 2024 payment year.

Future MVPs should have a better participation incentive structure. Physicians who participate in MVPs should also be held harmless from downside risk for at least the first two years of participation while they gain familiarity with a model that is more consistent with an APM and while CMS collects and shares data about whether MVPs are meeting their goal to improve quality and reduce unnecessary costs for the Medicare program and beneficiaries.

MIPS Performance Threshold

CMS should lower the MIPS performance threshold to a degree that avoids penalizing one-third of MIPS eligible clinicians.[5]  Sec. 101(c)(6)(D) of the statute requires CMS to set the performance threshold at the mean or median of the composite performance scores for all MIPS eligible professionals, and CMS proposes to maintain it at 75 points for the 2023 performance period.

As opposed to a pre-set formula, CMS is in a better position to determine each year whether physicians are ready to move to an increased performance threshold given the agency has access to all the previous year’s performance data. CMS may also decide to establish different thresholds for small and large practices.

Physician Access to Timely, Actionable Data

Physicians should be held accountable for the costs that are within their control and should have access to their claims data analysis to identify and reduce avoidable costs. Though Congress has taken action to give physicians access to their claims data, to this day physicians do not receive timely, actionable feedback on their resource use and attributed costs in Medicare. What is a lower-cost physician doing differently from a high-cost physician? For example, is it that they are better at care coordination? If we do not know the answer, we cannot achieve the goal of reducing avoidable costs and overuse. Physicians and specialty societies need access to their claims data analysis to identify variations in spending that are not accounted for by differences in patient needs and to eliminate unnecessary costs.

Furthermore, CMS needs to provide more detailed, specialty-specific and site-of-service specific breakdowns of MIPS performance data in the Experience Report or accompanying Appendix. The Public Use File (PUF) is not usable for national medical specialty societies that are evaluating opportunities for improvements in quality, cost, Promoting Interoperability, and Improvement Activities, nor in developing MVPs. The 2020 QPP PUF provides some site-of-service information, such as whether the physician bills in an Ambulatory Surgery Center or is considered hospital-based, but it is too limited.

Conclusion

Over time, underlying problems with the physician payment system and challenges with the QPP, and MIPS in particular, have revealed themselves much to the frustration of physicians and with a negative impact on patient care. Many of the issues outlined above cannot be addressed administratively and, therefore, require congressional action.  We appreciate that reaching consensus on solutions to these problems will not be an easy task. However, there is consensus on actions that Congress can take immediately that will better allow MACRA to fulfill its purpose of increasing value in the U.S. healthcare system.

Should you have questions or require additional information, please contact Irene Butler, ASE’s Vice President of Health Policy and Member Relations, at ibutler@asecho.org.

Sincerely,

Stephen Little, MD, FASE
President, American Society of Echocardiography

[1] Parke DW 2nd. The SGR Fix: Was It? Mo Med. 2015 Nov-Dec;112(6):408-9. PMID: 26821437; PMCID: PMC6168105.
[2] Some Medicare Advantage Organization Denials of Prior Authorization Requests Raise Concerns About Beneficiary Access to Medically Necessary Care. U.S. Department of Health and Human Services, Office of Inspector General. April 2022. https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf
[3] Khullar D, Bond AM, O’Donnell EM, Qian Y, Gans DN, Casalino LP. Time and Financial Costs for Physician Practices to Participate in the Medicare Merit-based Incentive Payment System: A Qualitative Study. JAMA Health Forum. 2021;2(5):e210527. doi:10.1001/jamahealthforum.2021.0527
[4] MGMA Annual Regulatory Burden Report – 2022. https://www.mgma.com/practice-resources/government-programs/mgma-annual-regulatory-burden-report-2022
[5] Centers for Medicare & Medicaid Services CMS–1770–P