By Murad Alam, MD
The Centers for Medicare and Medicaid Services (CMS) released the proposed 2014 Medicare Physician Fee Schedule in July, and although it is couched as a proposed rule — with a comment period before the final rule is issued — the proposal is indicative of coming changes in the payment and policy environment. AAD President Dirk Elston, MD, also outlined these coming changes in his recent President's Alert.
In the proposed fee schedule, CMS identified more than 200 codes for which the current total payment when furnished in an office or other nonfacility setting exceeds the total Medicare payment when the service is furnished in a facility. The facility can be either a hospital outpatient department or an ambulatory surgery center. CMS wants to bring these apparent inconsistencies into alignment, and this could significantly reduce the valuation of many dermatologic procedure codes.
The AADA will send a clearly worded comment letter disputing the appropriateness of this odd and technically unwarranted adjustment, but CMS is as a consequence proposing to cut 17311, Mohs micrographic technique, first stage (17311) by 7.64 percent; photochemotherapy with UV-B (96910) by 48.52 percent; and photochemotherapy with UV-A (96912) by 59.82 percent. Additionally, this policy could significantly reduce the technical component of pathology services, including common dermatopathology codes.
Regardless of the positive and negative aspects of the fee schedule, there are positive moves that we can each make to ensure our patients continue to be served and our practices continue to be viable.
One of the positive elements in the proposed fee schedule is the potential addition of two dermatology-related measures, including one for atopic dermatitis and another for psoriasis, bringing the total number of dermatology-related measures to six for the 2014 reporting year.
In terms of reimbursement for services, dermatology and many other procedurally based specialties are facing strong headwinds. This is happening even though skin cancer is more common than many other cancers combined, with a range of dermatologic treatments providing impressive cure rates and preserving function. In addition, skin problems are among the most common presenting complaints to all physicians — with dermatologists uniquely qualified to treat these cost effectively. Nonetheless, regulatory changes and budget constraints are increasingly hampering our ability to continue to provide quality care to our patients.
Dermatology, however, has some strengths that can help us meet our patients’ needs in an environment of scarcity. We provide diverse services, including numerous E/M services, which are under less pressure from payers. We have exceptionally committed physician volunteers in the Academy, and a committed, well-trained staff. Every move that takes us backward, and potentially undermines dermatologic patient care in the United States, is being vigorously contested. Efforts to educate legislators and regulators are continuous and urgent.
But the most important resource in dermatology is the thousands of talented, highly trained dermatologists who provide compassionate and effective care to their patients. Without the help of every U.S. dermatologist, dermatology will face a rough road.
Please consider being generous with your time in this period of great need for dermatology. Regardless of the positive and negative aspects of the fee schedule, there are positive moves that we can each make to ensure our patients continue to be served and our practices continue to be viable.
Speak up: Dermatologists who have the time and capacity may consider advocating for our profession on Capitol Hill and in their state houses. Legislators have a poor understanding of the value of dermatology, and we need to educate them about skin cancer, debilitating chronic diseases, and our specialized expertise. Often, there is no need to travel; you can meet with your federal legislators at their local district offices and communicate your concerns and thoughts.
Volunteer: Although we have a lobbying arm with the AADA, there is always room for more physician volunteers to support AADA committees and initiatives.
Evaluate from within: Because much of the move to curtail reimbursement is based on a perception that some services are over-utilized, we all need to self-monitor to ensure that we are performing procedures appropriately. This will protect us individually from audits and protect the specialty from excessive cuts in reimbursement.
Dermatology is a wonderful profession that has enriched all our lives. Our patients are the beneficiaries of the outstanding training we have received, as well as the research and advances our field has supported. Now, dermatology needs your help. Fortunately, there is much you can do.
Murad Alam, MD, FAAD, is chair of the AAD’s Health Care Finance Committee and is a professor of dermatology, otolaryngology, and surgery at Northwestern University’s Feinberg School of Medicine.
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