Absolutely MUST comment to CMS here!

This forum made possible through the generous support of SDN members, donors, and sponsors. Thank you.
Thanks for the info. I guess I don't understand then what the benefit is of "writing off" anything. In other words, why would anyone charge more than what is allowed by insurance or medicare/medicaid etc. ?

Because you don't want to have 10 different fee schedules.

Suppose Worker's Comp will pay you $900 for an epidural, do you really want to charge them Medicare rates? I'm sure they'd be happy to accept your discount.

Members don't see this ad.
 
Members don't see this ad :)
Were the cuts delayed until April? That seems to be what ASIPP is implying on their homepage.
 
Were the cuts delayed until April? That seems to be what ASIPP is implying on their homepage.

No. Only the SGR cuts are delayed. They did slightly increase the payment for in office stim to $1,349 for 1 lead and $2,023 for 2 lead trial. (It's not getting the L code back, but it is an increase of $100). Conversion factor goes up to 35.8228 until April. Then it could all change again with the SGR reform bill being proposed.
 
I'm having my patients sign a letter and then one of my girls is filling out and sending the capwiz letter online. She is also submitting a statement written by myself on the CMS comment link on their behalf. I think the comments are up to 200+ now. Everyone needs to keep submitting comments to that link you posted emd
 
Well I can try but I tend to agree with several others on here.

My comments would only matter if I was the chief editor for cnn/msnbc threatening to write the RNC a $20 million dollar check, endorse a republican for president and have my debate moderators tag team the democrat candidates in 2016 if they don't fix the fee schedule. Anything less than that and I'm probably wasting my time. But here's to trying!
 
What many of us do not understand is that most of the public feels we are overpaid and they have a claim to our income and property, this is also the platform of the Left, and if CMS cared what we thought they would not be passing a new rule that, in effect, you can't opt out of Medicare.
 
I'm having my patients sign a letter and then one of my girls is filling out and sending the capwiz letter online. She is also submitting a statement written by myself on the CMS comment link on their behalf. I think the comments are up to 200+ now. Everyone needs to keep submitting comments to that link you posted emd

Is that one of your daughters, your secretaries, or your mistresses? :laugh:
 
At least one of the big boys is lending a hand



Medtronic, Inc.
7000 Central Avenue NE
Minneapolis, MN 55432
www.medtronic.com
December 30, 2013
Ms. Marilyn Tavenner, Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1600-FC
Room 445-G, Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20210
Re: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY 2014
Dear Ms. Tavenner:
Medtronic is the world’s leading medical technology company, specializing in implantable and interventional therapies that alleviate pain and restore health. We work with health care providers to ensure patients have access to high quality care and effective, innovative medical technologies in appropriate care settings. Our Neuromodulation Division provides pain solutions for patients including intrathecal drug delivery and spinal cord stimulation therapies.
In this interest, we appreciate the opportunity to comment on the CY 2014 interim final RVUs for Interlaminar Epidural procedures (CPT codes 62310, 62311, 62318, 62319). In addition to use with epidural injections, CPT codes 62311 and 62319 are also used for intrathecal drug delivery trials. We are concerned that the significant reduction in payment for these procedures will limit access to these important treatments and compromise the viability of many US pain practices.
For CY 2014, CMS received AMA RUC recommendations for the work RVUs and direct practice expense inputs for the Interlaminar Epidural procedure codes. CMS significantly reduced the AMA RUC work recommendations for all these codes and accepted the direct practice expense inputs. As the table below indicates, CMS did not accept any of the RUC recommended work RVUs and decreased all the work RVUs, resulting in percent change decreases ranging from -24.7% for CPT code 62319 to -61.9% for CPT code 62310.
CPT Code
CY 2013
Work RVUs
AMA RUC Recommended Work RVUs
CY 2014
Work RVUs
Percent Change in Work RVUs

62310
1.98
1.68
1.18
-61.9
62311
1.54
1.54
1.17
-31.6
62318
2.04
2.04
1.54
-32.5
62319
1.87
1.87
1.50
-24.7
 
At least one of the big boys is lending a hand



Medtronic, Inc.
7000 Central Avenue NE
Minneapolis, MN 55432
www.medtronic.com
December 30, 2013
Ms. Marilyn Tavenner, Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1600-FC
Room 445-G, Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20210
Re: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY 2014
Dear Ms. Tavenner:
Medtronic is the world’s leading medical technology company, specializing in implantable and interventional therapies that alleviate pain and restore health. We work with health care providers to ensure patients have access to high quality care and effective, innovative medical technologies in appropriate care settings. Our Neuromodulation Division provides pain solutions for patients including intrathecal drug delivery and spinal cord stimulation therapies.
In this interest, we appreciate the opportunity to comment on the CY 2014 interim final RVUs for Interlaminar Epidural procedures (CPT codes 62310, 62311, 62318, 62319). In addition to use with epidural injections, CPT codes 62311 and 62319 are also used for intrathecal drug delivery trials. We are concerned that the significant reduction in payment for these procedures will limit access to these important treatments and compromise the viability of many US pain practices.
For CY 2014, CMS received AMA RUC recommendations for the work RVUs and direct practice expense inputs for the Interlaminar Epidural procedure codes. CMS significantly reduced the AMA RUC work recommendations for all these codes and accepted the direct practice expense inputs. As the table below indicates, CMS did not accept any of the RUC recommended work RVUs and decreased all the work RVUs, resulting in percent change decreases ranging from -24.7% for CPT code 62319 to -61.9% for CPT code 62310.
CPT Code
CY 2013
Work RVUs
AMA RUC Recommended Work RVUs
CY 2014
Work RVUs
Percent Change in Work RVUs

62310
1.98
1.68
1.18
-61.9
62311
1.54
1.54
1.17
-31.6
62318
2.04
2.04
1.54
-32.5
62319
1.87
1.87
1.50
-24.7

My Medtronic rep sent me this. I think it's great. Whether it will help or not, I don't know. Did SJ or BS do any lobbying in our favor? If not, why not?

Kudos to Medtronic for at least trying to have our backs a little bit.
 
i sent that Medtronic letter to both SJ and BS and asked them if they had sent anything similar. They both said they had. Who knows?
 
I think this was in Medtronics interest as the outpatient pump trials would be affected unlike st Judd and bs
 
whats that interlaminar epidural catheter code again?
 
Damn who is submitting this statement? Nice work but about 1700 of the 1800 comments are this one. Wonder if they'll just read it and dismiss. Not that I have any better ideas..

Dear Administrator Tavenner:
I’ve just learned from my doctor that starting January 2014, Medicare reimbursement rates for critical pain management procedures (CMS-1600-FC) will be drastically reduced. I am very concerned that this will likely interfere with my ability to receive quality pain management services in my local community. My pain is managed by experienced medical staff that treat my pain using a number of helpful treatments and procedures that allow me to be more active and engaged in my daily life. As a taxpayer, I ask you to not implement these policy changes.
As explained to me by my doctor, these changes are part of several revisions to the “Payment Policies under the Physician Fee Schedule” that were released three weeks late due to the government shutdown. This unfair delay gives my doctor’s office only one month to prepare for significant cuts to their reimbursement. I am very worried that these policies will reduce access to my local pain doctor and may force them to close offices and eliminate other services as a result of the reductions in payments for these treatments. I am concerned that if they are forced to lay off staff, I will have to wait longer to get an appointment and receive test results. I am also afraid that I will have to use a hospital for my pain services which is much more expensive for me as a patient and a taxpayer.
I ask you revise or eliminate the pain management related fee reductions and to not implement these policies that will cost me the federal government more money in the long run.
 
Just sent this to all the major newspaper carriers in the country. Probably won't do anything but makes me feel better.....


To whom it may concern,


As a reader and fan of your paper, I would like to share a physician's perspective on the recent changes in healthcare and specifically pain management.

Annually my field receives cuts between 5-20% for nearly every procedure we provide. This year however, CMS (The Center for Medicare and Medicaid Services) has decided to bless office based practices with a whopping 60% reduction in reimbursement for our most commonly performed procedures, epidural steroid injections. Now, one could argue that the risks assumed and skills needed to perform these highly technical procedures are worth far more than the measly ~$100 afforded by CMS as of 2014. However, what is more concerning is CMS' decision to simultaneously preferentially increase reimbursement for these same procedures when done in the hospital setting. A simple epidural in the office is now reimbursed near or below cost at approximately $100 leaving only $30 for overhead and expenses ($70 physician fee). This same procedure when done in the hospital however is reimbursed ~$670.

As many office based private practices will be unable to provide these services at the current reimbursement rates, patients will be forced into the less efficient and more costly hospital setting to receive these treatments at 6-7x the cost! This does not seem to mesh with the "Affordable Care Act". If the intent was to limit the performance of these procedures, CMS was unsuccessful and misguided. Just last year Sebelius decided against limiting performance of these procedures to properly
trained physicians (fellowship trained and board certifiied in Pain Medicine). Instead, she decided to leave it to the states to decide whether untrained individuals such as CRNAs could bill for these services. I currently know several NPs in my area performing these potentially dangerous and meticulous techniques with no training whatsoever! Very scary.

This is just one example amongst many in my field that will unfortunately lead to increases in individual patient and taxpayer costs and waste. It is an understatement to say that I am saddened by our government's poor and
misguided attempt to rein in costs which will ironically result in just the opposite. To compound the issue, as these alternative treatment options become financially unrealistic for pain physicians to provide, we will be forced
to use more and more dangerous opioid pain medications in our progressively limited armamentarium adding to the burgeoning opioid epidemic. Thank you for your time. I pray that something can and will be done to stop these wasteful and potentially harmful initiatives.



Sincerely,
 
Ok I realize I'm apparently the only one posting on this thread but I had a question for ya'll. 1) How likely is it that anything will come of all our letters, comments to CMS, complaining, crying etc? and B) Is there a certain time period in which we can expect some type of response?

The reason I ask is that I have friends asking me what came of my stint on the news regarding the cuts. I tell them I'm waiting on the final decision to increase the minimum wage and then I'm applying to McDonalds
 
Top