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2000 Medicare fee schedule is a mixed bag for ophthalmology
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Assuming that Y2K fears do not come to fruition, and that the millennium brings nothing more catastrophic than hangovers and headaches, on Jan. 1 the Health Care Financing Administration (HCFA) will implement its final 2000 Medicare fee schedule and interim relative values will be established.
HCFA published its proposed 2000 Medicare fee schedule in the Federal Register in July. Since then, the Agency has reviewed comments from the Relative Update Committee (RUC), the Practice Expense Advisory Committee (PEAC) and other interested parties, including the American Academy of Ophthalmology (AAO) and the American Society of Cataract and Refractive Surgery (ASCRS).
Non-physician clinical staff costs
According to ASCRS, one change included in the proposed rule that would most affect reimbursement rates for ophthalmic procedures has to do with further refinement of practice expense RVUs.
In the proposed rule, HCFA excludes the costs of clinical staff in the facility setting from the data used in calculating the practice expense payment for medical services. In a letter to HCFA’s acting administrator, Michael Hash of ASCRS states, “The top-down methodology adopted by HCFA uses the American Medical Association’s Socioeconomic Monitoring System [AMA SMS] data, which includes the total practice expense costs per specialty. Included in that total is the cost of all clinical staff who assist both in surgery and in the office. Since the costs are already included in the AMA SMS data, and they are real costs to the practice, they should not be removed from the CPEP data.”
While ophthalmology as a whole would see a 1% increase as a result of this proposed change, surgical services performed in a hospital or ambulatory surgery center (ASC) would see another decrease in the practice expense RVUs, according to ASCRS. Cataract removal and lens insertion, (CPT 66984) would decrease by 3% and postop cataract laser surgery (CPT code 66821) would decrease by 6% when performed in a hospital or ASC, but increase by 3% in an office setting.
Diagnostic reimbursement discrepancies
The AAO also submitted comments to HCFA detailing suggested changes to the proposed Medicare fee schedule for 2000. In its letter, the AAO stated that all ophthalmic diagnostic CPT codes, such as visual fields, must be returned to ophthalmology’s pool of practice expense dollars. Currently, all diagnostic and radiological services are in a pool that is paid at a much lower practice expense rate than all other ophthalmology services, according to AAO’s Federal Affairs Division spokesperson Sandra Remey. “Because ophthalmology’s practice costs per hour are much higher than the rate assigned to the radiology and pathology services, ophthalmic diagnostic tests are being reimbursed at a rate lower than the actual cost of providing the service. Returning the diagnostic services to ophthalmology’s pool of practice expense dollars will result in an increase of more than $100 million for those services,” Ms. Remey stated in an AAO press release.
In addition to the practice expenses, the AAO highlighted problems with the malpractice relative value formula and recommended shortening global periods to 10 days for three laser procedures: YAG, iridotomy/iridectomy and trabeculoplasty by laser surgery. “These laser services are performed primarily in the office or ASC, have short recovery times and stable operative sites. All the data incorporating visits occur within this timeframe, and any additional visits are spent treating the underlying chronic disease,” the AAO’s formal comments state. The shortened global period would mean more money for ophthalmology by allowing payment for services provided after surgery that are unrelated to the procedures that were performed.
Catherine Cohen, AAO vice president of federal affairs, described AAO’s comments as one more rung on the ladder toward fair and accurate reimbursement for ophthalmology. “Our letter is yet another attempt to convince HCFA to apply all edits approved in April by the AMA/Specialty Society Relative Value Scale Update Committee’s Practice Expense Advisory Committee and improve the new 2000 physician fee schedule for ophthalmology.”
For Your Information:
- Catherine Cohen can be reached at the American Academy of Ophthalmology, Federal Affairs Division, 1101 Vermont Ave. NW, Ste. 700, Washington, DC 20005; (202) 737-6662; fax: (202) 737-7061; Web site: www.eyenet.org. Ms. Cohen did not participate in the preparation of this article.
- Michael Hash can be reached at the American Society of Cataract and Refractive Surgery, 4000 Legato Road, Ste. 850, Fairfax, VA 22033; (703) 591-2220; fax: (703) 591-0614. Mr. Hash did not participate in the preparation of this article.
- Sandra Remey can be reached at the American Academy of Ophthalmology, Federal Affairs Division, 1101 Vermont Ave. NW, Ste. 700, Washington, DC 20005; (202) 737-6662; fax: (202) 737-7061. Ms. Remey did not participate in the preparation of this article.