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Regulatory Advocacy

The AAO-HNS has a long history of working closely with regulatory agencies (e.g., Centers for Medicare & Medicaid Services, U.S. Food and Drug Administration) to maintain our visibility and credibility with national representatives regarding federal regulatory issues.

We believe that advocacy is the key to defining the future of otolaryngology. Federal regulatory advocacy is a top priority of the AAO-HNS.

CMS Releases Final Rule for CY 2018 Medicare Physician Fee Schedule - 11/9/2017

On November 2, the Centers for Medicare and Medicaid Services (CMS) released the CY 2018 Medicare Physician Fee Schedule (MPFS). CMS finalized recommended work Relative Value Units for the newly developed endoscopic sinus surgery and balloon sinus dilation codes. A new AMA CPT Assistant on the new codes is being developed to provide members with guidance.

  • Read the final rule here
  • Review the CMS fact sheet here

Academy Comments on Proposed 2018 Hospital Outpatient Prospective Payment System Rule

On September 6th, the AAO-HNS submitted comments on the CY 2018 Medicare Program: Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems and Quality Reporting Programs proposed rule. The main issue that could impact AAO-HNS members is the proposed ASC payment for new bundled sinus codes. In the letter, the Academy recommended that CMS determine some other payment for these new bundled codes that more accurately reflects the costs and resources utilized by ASCs, offering to help CMS develop the new payment methodology. Other comments addressed the following issues: 1) CY 2018 Comprehensive Ambulatory Payment Classifications (C-APCs); 2) Imaging APCs; and 3) Changes for Computed Tomography (CT) under the Protecting Access to Medicare Act of 2014 (PAMA). To read the submitted comment letter, please click here.

CY 2018 Proposed Medicare Physician Fee Schedule Member Summary Released

On July 13, CMS posted the proposed rule for payments in the Medicare Physician Fee Schedule (MPFS) for calendary year (CY) 2018. In addition to payment and policy updates, the MPFS addresses a number of issues affecting Otolaryngologists. For CY 2018, CMS has generally proposed AMA Relative Update Committee's (RUC)-recommended work RVUs for new, revised, and potentially misvalued codes. CMS is proposing these values based on their understanding that the RUC generally considers the kinds of concerns CMS has historically raised regarding appropriate valuation of work RVUs. 

Specifically, for 2018, CMS proposes values for existing and newly developed Endoscopic Sinus Surgery (ESS) and balloon sinus dilation (BSD) codes. The codes were developed in conjunction with the American Rhinologic Society (ARS) and the American Academy of Otolaryngic Allergy (AAOA). The proposed values represent a decrease for the ESS codes ranging from -7.9% to -23.6%. The BSD codes, which had been surveyed in 2011, had values more consistent with the previous values. A table with the proposed CY 2018 Work RVUs for New, Revised, and Potentially Misvalued Codes including all of the ESS and BSD codes can be accessed here

Additionally, CMS proposes refinements to reimbursement for scopes with individual procedures, practice expense RVUs, discusses possible revisions to E/M guidelines to reduce the associated burden and better align E/M coding and documentation with the current practice of medicine, outlines provisions for Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging starting in 2019, aligns the Physician Quality Reporting System (PQRS) and Value-based Modifier (VBM) programs with the Merit-based Payment System (MIPS) reporting criteria, and proposes new modifiers for patient relationship categories under MIPS. 

For a more detailed summary of the proposed rule, members can access here

Academy Comments on Accredidation Organization Requirements in Medicare Hospital Inpatient Payment Proposed Rule
On June 13, the Academy, in conjunction with the Intersocietal Accrediation Commision (IAC), submitted comments to the Centers for Medciare & Medicaid Services (CMS) on the 2018 Medicare Hospital Inpatient Prospective Payment System proposed rule. The Academy and the IAC oppose the proposed requirement that accrediting organizations, such as the IAC, post final survey reports from the past 3 years online. The Academy believes this proposal imposes an undue administrative burden and releases potentially confusing inforamtion to patients. Access the comments

Final 2017 Medicare Fee Schedule

On January 5, the Academy submitted comments to Centers for Medicare & Medicaid Services (CMS) on the 2017 Medicare Physician Fee Schedule final rule. Topics addressed include: practice expense adjustments; revised global surgical data collection requirements; Appropriate Use Criteria for Advanced Diagnostic Imaging requirements; modifications to the Qualified Clinical Data Registry (QCDR) qualification requirements; and updates to the Value Based Modifier and Physician Feedback Programs. Access the comments

Academy Comments on CY 2017 HOPPS Final Rule
On December 22, the Academy submitted comments to CMS on the final rule for 2017 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center Payment Rate. In the comments, the Academy addressed point-of-care imaging access for patients and changes to Ambulatory Payment Classifications assignments. Read the comments.

Academy Comments on MIPS and APM Final Rule
On December 19, the Academy submitted comments to CMS in response to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Final Rule. The Academy commented on the reduced reporting requirements for the transition year; MIPS performance category criteria and scoring; QCDR and quality measure reporting requirements; and applicability of APMs to Otolaryngologists - Head and Neck Surgeons. Access the comments