The Medical Group Management Association has submitted comments to the Centers for Medicare and Medicaid Services in response to its proposed 2009 Physician Fee Schedule.
Among its recommendations, the MGMA calls for CMS to implement the 1.1 percent Medicare physician payment update in 2009 using the current 2008 conversion factor as the base rate.
In a letter to CMS Acting Administrator Kerry Weems, MGMA officials said the proposed physician fee schedule confirms the 5.4 percent reduction in Medicare physician reimbursement levels for services rendered on or after Jan. 1, 2009 as forecast by the CMS in a Feb. 29, 2008 letter to the Medicare Payment Advisory Commission (MedPAC).
MedPAC estimates that payments will be cut every year for the foreseeable future - a trend that it says will have grave consequences for the nation's healthcare system without legislative action - and has recommended that the current system be replaced with one that reflects a need for annual increases.
The MGMA is asking that CMS:
- withdraw its proposal to require physician offices providing diagnostic imaging services to enroll as independent diagnostic testing facilities, especially in light of the imaging accreditation provisions contained in the Medicare Improvements for Patients and Providers Act;
- delay implementing any changes to the Medicare enrollment process until a Web-based enrollment system is ready for use by providers;
- create educational programs on provider enrollment for contractors and providers to ensure that both sides understand the process;
- extend the Jan. 1, 2009, compliance date for the exemption for computer-generated facsimiles until most medical groups transition to the NCPDP SCRIPT standard (CMS should also augment its educational activities and regularly assess the readiness level of the industry);
- withdraw the complex and confusing proposals relating to the anti-markup rule and instead focus on implementing the requirements in MIPPA;
- and allow an appeals process for the 2007 Physician Quality Reporting Initiative (PQRI), provide medical associations with the 2007 and 2008 PQRI data set files, withdraw proposed changes to the group measure participation option and only publish on its Web site the names of clinicians and group practices that satisfactorily participate in PQRI and earn the bonus incentive.
The proposed rule, titled "Revisions to Payment Policies Under the Physician Fee Schedule and Other Part B Payment Policies for Calendar Year 2009; and Revisions to the Amendment of the E-Prescribing Exemption for Computer Generation Facsimile Transmissions; Proposed Rule," was published in the July 7, 2008 Federal Register.
Do you have any comments on the proposed rule? Send your thoughts to Associate Editor Chelsey Ledue at chelsey.ledue@medtechpublishing.com.