On Wednesday, November 27, the Centers for Medicare and Medicaid Services (CMS) released its 2014 Physician Fee Schedule Final Rule containing its decision whether or not to change the established 2013 EMG and NCS relative value units (RVUs) for 2014. In a partial victory, two of the EMG codes received a slight reimbursement increase. However, despite significant pressure from AANEM and other physician groups, CMS did not increase the reimbursement rates for the NCS codes.
“We are obviously very disappointed that CMS did not follow the refinement panel’s recommendation to accept the higher reimbursement values agreed to by the RUC Committee, but we are pleased that we did receive a slight increase on the two EMG codes under review,” said Kathleen Micheletti, government relations director. “However, we will continue to work on developing alternate strategies to address the long-term effects of these drastic cuts. Our recent visits to the hill are an important step in bringing the issues facing physicians who treat patients with neuromuscular disorders to legislators’ attention. We will be increasing these efforts in 2014.”
Also contained in the rule were changes for some evoked potential codes, and inter-operative monitoring (IOM) “G” codes. Of special note, the SGR conversion factor is predicted to be 20% lower, which will cause a significant decrease in Medicare physician reimbursement unless Congress acts again with a short term fix, or a total repeal of the SGR formula, before January 1, 2014.
Coding Toolkit: Analysis of the 2014 CMS Physician Fee Schedule
Details about the EMG and NCS codes reviewed by the refinement panel and finalized in the 2014 physician fee schedule may be found at www.aanem.org/coding-toolkit. Click on "Analysis of the 2014 CMS Physician Fee Schedule."
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Other News Related to CMS
AMA Responds to CMS' Proposed 2014 Physician Fee Schedule
News item posted on 8/14/13
In its recently released report that outlines key provisions of the 2014 Medicare Physician fee schedule, the American Medical Association (AMA) accuses the Center for Medicare & Medicaid Strategies (CMS) of proposing an “arbitrary” policy that would lower payment for more than 200 services that Medicare pays more for when performed in a physician’s office compared to the reimbursement for the same procedure when it is performed in a hospital outpatient setting.
Download AMA’s summary of key provision of the 2014 Medicare physician fee schedule (PDF)
Eight EDX codes are included in the list prepared by CMS. The AMA estimates that, if enacted, this proposal would result in a 4% decrease in revenue for a neurology practice. Physiatry practices are predicted to see a 3% decrease in revenue. The AMA has vowed to aggressively oppose this proposal and will seek to delay implementation until the impact can be fully evaluated by AMA staff and the societies who bill the codes. The AANEM is working with the AMA, AAN, AAPMR, and ACNS to calculate the impact of CMS’ proposed policy to EDX providers.
The AMA’s report also highlights concerns with proposed policies for quality reporting, physician feedback reports, payment for investigational devices, and calls attention to the fact that CMS is seeking comment on whether Medicare should allow chiropractors to bill Evaluation & Management (E&M) services.
The public has until September 6, 2013, to submit comments to CMS.
CMS Releases Proposed 2014 Physician Fee Schedule
News item posted on 7/25/13
On July 8, 2013, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule that would update payment policies and rates for services furnished under the Medicare Physician Fee Schedule after January 1, 2014.
The document contains a proposal to reduce rates for more than 200 “misvalued” CPT codes, so that payments for services provided in a physician’s office do not exceed any payment for the same service provided in a hospital outpatient department or ambulatory surgical center. Eight EDX codes are included in the list of misvalued services, including four where EMG is performed without an NCS and two related to IOM.
Along with our colleagues at AAN, AAPMR, and ACNS, AANEM will be commenting on this proposal. All comments will be made available for public viewing. In addition, the proposed rule is available for public inspection, and anyone may submit comments to CMS. Comments may be submitted electronically, by regular or express mail, mail or by hand. They must be submitted by September 5.
These comments are used to help set the final rule for the Physician Fee Schedule, which is expected to be released in early November.
Download the proposed rule (PDF)
News item posted on 7/12/13
CMS Convenes Refinement Panel on EMG/NCS
AANEM received notice that our request for a review of the work relative value units (RVUs) assigned to two EMG CPT codes and the seven new Nerve Conduction (NCS) CPT codes will undergo a review by an independent Refinement Panel in late August.
“We are very pleased that our aggressive lobbying efforts have resulted in acknowledgement by the Centers for Medicare & Medicaid Services (CMS) that these drastic cuts need further scrutiny,” said Kathleen Micheletti, government relations director for AANEM.
Refinement Panels are comprised of four Medicare Contractor Medical Directors, one or two members from the presenting specialty, one or two members from a related specialty who are expected to have some knowledge about the services under review, one representative from the American Academy of Family Physicians, and one representative from the American College of Physicians.
CMS can either accept or reject the Refinement Panel decision. Any decision by CMS will be included in the Medicare Final Rule due out on November 1, 2013.
AANEM staff continue to work with the American Academy of Neurology and the American Academy of Physical Medicine and Rehabilitation to finalize presentations for the upcoming Refinement Panel.
April 1 AANEM Meeting with CMS
News item posted on 4/5/13
On April 1, representatives from AANEM, American Academy of Neurology, American Academy of Physical Medicine and Rehabilitation, and American Physical Therapy Association met for a second time with Jonathan Blum and his staff from the Centers for Medicare and Medicaid Services (CMS). Blum continued to express interest in data sharing and has asked for more ideas on how the negative outcomes of CMS’ significant cuts to EDX relative value units could be tracked via claims data.
Read about AANEM's meeting with CMS on Dec. 20, 2012
The AANEM Board of Directors will discuss this request at its April 11 meeting. AANEM, along with the other organizations, will send a follow-up letter to CMS next week that outlines additional data elements we believe will highlight access and quality of care issues as a result of the cuts.
CMS will notify us if our request for a refinement panel hearing will be granted on May 1. Refinement panels are convened when a second level of review has been determined necessary to validate or dispute relative value units assigned by the AMA RUC and/or CMS. The panel is expected to convene in August, with its recommendations made public before the 2014 fee schedule is released. The AANEM is hopeful we will be able to present our reasons why the cuts were inappropriate.