Summaries of CMS Regulations and the Academy's Comment Letters

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Comment Letters


Summaries of Regulations and their Impact on Otolaryngology - Head and Neck Surgery


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Academy's Comment Letters on CY 2013 MPFS and HOPPS/ASC Final Rules

The Academy submitted comments to CMS by the December 31st deadline on the final rules for the CY 2013 Medicare Physician Fee Schedule and the CY 2013 HOPPS/ASC Payments. In the letters, the Academy addressed issues that affect Otolaryngology- Head and Neck Surgery. Click below to see each comment letter:

Academy's CY 2013 Fee Schedule Final Rule Comment Letter

Academy's CY 2013 HOPPS/ASC Final Rule Comment Letter

Academy's Comment Letters on CY 2013 MPFS and HOPPS/ ASC Proposed Rule 

On August 28th, 2012, we submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rules for the CY 2013 Medicare Physician Fee Schedule and CY 2013 HOPPS/ ASC Payment. In the letters, the Academy addressed issues that affect otolaryngology- head and neck surgery including quality reporting initiatives, the Sustainable Growth Rate (SGR), and Outpatient and Ambulatory Surgical Center payment. Click below to see each comment letter:

Academy's Comment Letter on the Proposed Rule for CY 2013 Medicare Physician Fee Schedule (MPFS)

Academy's Comment Letter on the Proposed Rule for CY 2013 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment Rate

Academy’s Comment Letter on the Final Rule for CY 2012 Medicare Physician Fee Schedule
On January 2, 2012, we submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the final rule for the CY 2012 Medicare Physician Fee Schedule. In the letter, the Academy addressed the Sustainable Growth Rate (SGR) formula, potentially misvalued codes, quality reporting initiatives and other important issues that affect otolaryngology- head and neck surgery.

Academy's Comment Letter on the Proposed Rule for CY 2012 Medicare Physician Fee Schedule
On August 30, 2011, we provided comprehensive feedback to CMS on the proposed rule for the CY 2012 Medicare Physician Fee Schedule (PFS). In the letter, we addressed the evaluation of potentially misvalued codes, quality reporting initiatives and many other important areas that impact otolaryngology – head and neck surgery.  

Academy’s Comment Letter on the Proposed Rule for CY 2011 Medicare Physician Fee Schedule
On August 23, 2010 we submitted a comment letter to CMS on the proposed rule for the CY 2011 Medicare Physician Fee Schedule. In the letter, we addressed the elimination of consultation codes, the sustainable growth rate, the resourced-based practice expense relative value units, potentially misvalued codes under the PFS and many other important areas.

Academy's Comment Letter on the Proposed Rule for CY 2010 Medicare Physician Fee Schedule (MPFS) 
On August 31, 2009 we submitted a comment letter to CMS on the proposed rule for the CY 2010 MPFS. In this letter, we urged CMS to separately reimburse for canalith repositioning, supported the CMS's use of data from the Physician Practice Information survey (PPIS) to compute the practice expense component, and addressed other important issues.

Summaries of Regulations and their Impact on Otolaryngology - Head and Neck Surgery

Academy Releases Summaries of Key Provisions for the 2013 Final Rules for the Medicare Physician Fee Schedule and Hospital Outpatient / Ambulatory Surgical Centers.
The Centers for Medicare and Medicaid Services (CMS) released the final 2013 Medicare Physician Fee Schedule (MPFS) and the finalized payment rates for Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Centers (ASCs). The Academy has reviewed the MPFS final rule and has released a detailed summary outlining many of the key provisions contained in the rules that affect Otolaryngologists- Head and Neck Surgeons. The Academy has additionally reviewed the OPPS and ASC final rule and has released a summary outlining key provisions below.

Academy Summary of 2013 finalized Medicare Physician Fee Schedule (11/15/12)
Academy Summary of 2013 finalized HOPPS and ASC Payment (11/29/12)


Academy Releases Summary of Key Provisions for the 2013 Proposed Rules for the Medicare Physician Fee Schedule and Hospital Outpatient/ Ambulatory Surgical Centers

CMS released the proposed 2013 MPFS and the proposed payment rates for  HOPPS and  ASCs.

The Academy reviewed the MPFS proposed rule and the proposed HOPPS/ASC rule and have released a detailed summary outlining many of the key provisions containted in the rules that affect Otolaryngologist- Head and Neck Surgeons.

Academy Summary of 2013 proposed Medicare Physician Fee Schedule
Academy Summary of 2013 proposed HOPPS and ASC Payment

Click below to see the proposed MPFS rule and proposed HOPPS and ASC payment rate rule:

2013 proposed Medicare Physician Fee Schedule (MPFS)
2013 proposed payment rate for Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center (HOPPS and ASC)

CMS Releases Final Rule Outlining Changes in Provider Enrollment Requirements for Ordering Referring Physicians
On April 27th, the Centers for Medicare and Medicaid Services (CMS) issued a final rule outlining changes in provider enrollment for ordering and referring physicians in Medicare. The rule clarifies that these requirements will only apply to those who order or certify: durable medical equipment, prosthetics, orthotics, and supplies (DEMPOS); clinical laboratory services; imaging; and home health services.

CY 2012 MPFS Final Rule
CMS released the final rule for the CY 2012 Medicare Physician Fee Schedule. In the final rule, CMS estimates a 27.4% reduction in Medicare payment compared to the CY 2011 MPFS due to the Sustainable Growth Rate (SGR) if Congress does not intervene. The Academy has repeatedly called for the replacement of the SGR. CMS also responded to some of the Academy's comments to CMS on the proposed rule. To note, CMS decided not to change the proposed lower values for thyroid/ parathyroid and submandibular gland excision codes, maintaining its position that physician outpatient work following a 23 hour stay is less intense than inpatient work. CMS believes the valuation of the codes that fall into the 23 hour stay category should not reflect physician work associated with inpatient services. Also, CMS decided to deduce the sinus ostial dilation (CPT 31295-31297) practice expense values of the sinus surgery balloon supply kits to 0.5 units per procedure on an interim basis for 2012. Health Policy staff produced this detailed summary for member and will submit comments to CMS of issue by the Jan. 3rd deadline.  

CMS Issues Proposed Rules to Address Unneccesary, Obsolete, or Excessively Burdensome Medicare and Medicaid Regulations To see a summary of provisions affecting Otolaryngology- Head and Neck Surgery, click here

Potential 1% Increase for Otolaryngology - Head and Neck Surgery in the CY 2012 MPFS Proposed Rule
The Academy’s Research, Quality Improvement & Health Policy staff have summarized the payment and quality aspects of the CY 2012 proposed rule for the MPFS pertinent to our specialty.  Based on this analysis, the specialty may see a 1% increase (not including the potential overall 29.5% cut) in CY 2012. The Academy will submit comments to CMS advocating for our members’ interests. 

CY 2011 MPFS Final Rule
We have summarized the impact of the final rule for the CY 2011 Medicare Physician Fee Schedule (MPFS) so that you are aware of important changes that will affect you as an otolaryngologist - head and neck surgeon.

CY 2011 MPFS Proposed Rule
To ensure that you are aware of the potential changes in the MPFS that might affect you and your practice for services you perform on or after January 1, 2011, the Health Policy department has drafted a summary of the proposed rule for CY 2011 and its impact on otolaryngology - head and neck surgery. The Academy sent a comment letter (see link above) to CMS addressing our position on the proposed rule.


Page Last Updated on November 15, 2012

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