|
 |
|
Public Policy Issues
October 14, 2008 - The following article link has been made available to us by Osteoporosis International for a three-month period. The article is published in Osteoporosis Interational, Osteoporos Int (2008) 19:1505–1509.
ISCD Objects to Proposed Medicare Rule On August 27, 2008 the ISCD filed comments on the latest Medicare proposed rule, CMS-1403-P. The rule included several provisions that threaten our ability to care for osteoporosis patients. In addition to the administrative burden on physicians, the adoption of this proposed rule represents another assault on the availability of quality DXA. The ISCD argued against the adoption of a new rule that would require physicians performing diagnostic imaging in their offices to enroll as an independent diagnostic testing facility (IDTF) and comply with certain standards in order to be eligible for reimbursement. The proposed rule in part focused on the qualifications for both physician and non-physician personnel performing these imaging procedures. CMS indicated that the impetus for this proposal was the result of comments by personnel at IDTFs who bristled under new requirements that only applied to imaging procedures performed in their facilities. They argued that regulations applying to imaging procedures should apply across the board regardless of where the location of physician performing it. When implementing the rule on IDTFs, a majority of Medicare carriers require the supervising physician for DXA scans be limited to radiologists and/or internists. In addition, a majority of these carriers have not recognized the ISCD Certification of technologists. We argued that the rule would exclude a substantial and highly skilled portion of the provider community. ISCD also opposed the inadequate reimbursement rate for DXA and urged CMS to reevaluate the reimbursement for DXA to more accurately reflect the cost of providing the service. Click here to read the full text of the ISCD’s comments to CMS-1403-P. CMS Proposes New Rules Regarding Imaging Services in Physicians’ Offices. Impact on DXA Testing is Unclear. On June 30, 2008 CMS proposed new rules that may have far-reaching implications for physicians providing diagnostic imaging services, including central DXA, to Medicare beneficiaries in their offices. CMS-1403-P would require physicians providing these services in a non-facility setting to comply with regulations that already apply to Independent Diagnostic Testing Facilities (IDTFs).1 The CMS proposed rule would require physicians performing diagnostic imaging services in their offices to:
It is unclear how this proposal would be interpreted by local Medicare carriers and how it would affect physicians and technologists providing DXA testing. Carriers have interpreted the IDTF regulations in a very restrictive manner by requiring that most imaging procedures be supervised by a radiologist. The proposed rule would also impose minimum standards on technologists if the imaging procedure is performed in a state that does not regulate radiologic technologists. CMS has requested comments and feedback regarding this proposed rule. The rule specifically requests comments by individuals and groups to respond to the following questions:
These questions make it clear that the parameters of the proposed rule have not yet been finalized. ISCD will submit comments to CMS on the proposed rule by the August 28 deadline and will keep you posted regarding its status. As soon as ISCD has thoroughly analyzed the CMS proposal and developed our response, we will call upon our members to submit comments to CMS by the August 28 deadline. If you have questions or want to provide feedback on this issue, please contact ISCD Legislative Counsel, Donna Fiorentino. Click here to view a relevant excerpt of CMS 1403-P.
DXA Cuts Not Addressed in Medicare Package On July 15, Congress voted to override President Bush’s veto of the long-awaited physician fix—the legislation that will ward off the 10.6% across the board cuts for physician services under the Medicare program. The bill will result in a physician payment update of 0.5% through December 31, 2008 and 1.1% increase for the 2009 calendar year. The recurring Medicare physician fee crisis is the result of a cost control formula that was put into place in 1997. While there was agreement among Congressional leaders that the scheduled fee cuts needed to be reversed, battle lines were drawn between Congressional Democrats and Republicans as to how to pay for this moratorium; Democrats favored drawing money from the Medicare Advantage Plans as a way to fund the moratorium while Republicans were opposed to using this as a funding source. In the end, enough Republicans split with their leadership to pass the legislation. While Congress addressed the Medicare cuts, a remedy for the DXA cuts was not included in this larger Medicare package. If left uncorrected, central DXA reimbursement in the non-facility setting will drop to approximately $76 in 2009 and $56 in 2010. Because of the efforts of the ISCD and our partners, bills to address reimbursement cuts to DXA were introduced in both the House and the Senate with bi-partisan support. By targeting members of Congress on key committees through direct visits to Washington as well as intensive letter writing, e-mail and phone campaign, we now have raised awareness of the critical nature of this issue. While we have made substantial progress to address the DXA issue, more work needs to be done. ISCD will continue to work with our partners this year to identify other legislative options so that DXA services are reimbursed appropriately and patient access to care is not threatened. Additionally, we are developing strategies to address this issue with the new Administration and Congress in 2009.
The DXA Bill is Here - Act Now On March 4, 2008, U.S. Senators Ken Salazar (D-CO) and Olympia Snowe (R-ME) filed a bill to remedy the Medicare cuts to DXA. S. 2702, the "Medicare Fracture Prevention and Osteoporosis Testing Act", is the Senate companion to H.R. 4206, the bill introduced in the House by Representative Shelley Berkley (D-NV) last fall. Introduction of the DXA bill in the Senate marks an important step in our battle to restore DXA reimbursement to appropriate levels. Senators Salazar and Snowe need the support of their Senate colleagues to give the bill necessary momentum and to show Senate leadership that osteoporosis testing is an issue that requires their immediate attention. Visit our Advocacy Web site to easily send letters to your Senators asking for support of this bill. Click on Bill Cosponsors below to see if your Senator is one of the 9 members of Congress that has signed on as a bill sponsor. If they aren't listed, contact your Senator and urge them to sign on as a cosponsor to this important piece of legislation. On November 15, 2007, Representative Shelley Berkley (D-NV) introduced H.R. 4206, the "Medicare Fracture Prevention and Osteoporosis Testing Act of 2007." The bill will freeze DXA rates at 2006 levels until a study of the effect of these cuts on patient care is completed. At this time, Rep. Berkley needs the support of her Congressional colleagues to give this bill added momentum. Click on Bill Cosponsors below to see if your Congressional Representative is one of the 67 members of Congress that has signed on as a bill sponsor. If they aren't listed, contact your Congressional Representative and urge them to sign on as a cosponsor to this important piece of legislation. Links to a DXA Fact Sheet and Talking Points for your calls are posted below. A PowerPoint Overview - DXA Cuts Click the link below to view or download a PowerPoint Overview of the DXA Cuts. This document illustrates the problems created by the DXA cuts and the need to restore reimbursement to appropriate levels. It can be used with local organizations and groups to generate participation in our grassroots advocacy campaign.
We Need Your Stories As Congress returns from the holiday recess, ISCD and members of the DXA task force are continuing to press for a remedy to the DXA cuts. On February 25 and 26, ISCD will join AACE in Washington to visit key members of Congress to urge passage of Representative Berkley’s bill, H.R. 4206, the Medicare Fracture Prevention and Osteoporosis Testing Act of 2007 in the House and a companion bill in the Senate. In the past year, ISCD and our partners have developed critical survey and statistical data to support our legislative position. While this information is imperative, we find that members of Congress are anxious to know how the cuts are affecting their constituents. You can help. We are collecting stories about practices who have already stopped DXA testing or have cut back services as the result of the Medicare cuts. An example of one such story from one of our Michigan members is listed below. If you have a story to tell, please contact Donna Fiorentino at dfiorentino@iscd.org.
Visit the ISCD Advocacy Web site now, login (or register) and “Take Action” as an easy way to contact your Congressional Representative online. It only takes a few minutes to help. Go to the ISCD Advocacy Web site See your stories by stateDXA Study Findings from The Lewin Group ISCD, along with our sister societies, recently commissioned a study by The Lewin Group to determine the cost of performing a DXA and VFA procedure in the physician office setting. The study also looked at program costs associated with reversing Medicare payment cuts for these procedures. The Lewin Group study concluded that after accounting for savings assoicated with avoided fractures and the cost of treating at-risk individuals, restoring DXA payment rates to the 2006 level will ACTUALLY save the Medicare program $1.14 billion over five years. Click here to read the executive summary or the complete report. If you have questions, please contact Donna Fiorentino, Manager of Public Policy Affairs at dfiorentino@iscd.org. Related Articles Below is a link to a compilation of articles related to Public Policy issues/efforts. Return to the Advocacy Home Page
|
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
