Last week the final 2016 Physician Fee Schedule (PFS) and Medicare Hospital Outpatient Prospective Payment System (HOPPS) payment rates were released by the Centers for Medicare and Medicaid Services (CMS). The SVU Advocacy Committee along with SVU counsel have reviewed and compared the final rates and there is a significant cut to the 2016 vascular ultrasound rates when compared to the 2015 rates – up to a 32 percent rate reduction in the most commonly used vascular testing codes on the HOPPS side and up to a 19 percent reduction in arterial duplex and visceral vascular testing codes on the PFS rates.
Why did this happen?
This reduction is largely driven by Congressional budget cuts and the CMS' decision to consolidate seven vascular Ambulatory Payment Classifications (APCs) for HOPPS studies into three classifications. Such restructuring appears to have reduced the APC payment rates for most vascular ultrasound services, while not reducing radiologic and cardiac ultrasound services. This restructuring occurred despite a concerted effort by SVU to prevent this restructure through comment letters and discussions with CMS.
SVU's past efforts have included fighting the “zero work-pool” cuts in the late 90’s that would have cut reimbursements in half, to mitigating cuts proposed in the Deficit Reduction Act (DRA) in 2005. SVU’s Advocacy efforts alone and with other organizations have averted potentially disastrous cuts to our reimbursements. SVU’s efforts have assured that we as members can continue to do what we love to do – provide quality vascular care to our patients.
What this means for you
Hospitals could reduce vascular technologist’s salaries, cut the amount of time to perform quality evaluations and slash budgets to offset these reductions. The effect of these arbitrary cuts will be disastrous to all technologists, vendors, physicians and patients. If hospitals cut salaries and benefits, so will physician practices and imaging centers. This is not a threat to SVU as an organization but to the field of vascular testing as a profession.
Next steps
The SVU Advocacy Committee is in the process of further assessing the final 2016 PFS and HOPPS rules and will submit additional comments to CMS to address certain finalized policies, including the restructuring of ultrasound APCs that impact vascular ultrasound. Although not a guarantee for success, SVU trusts that CMS will respond favorably to our proposal if its impact is clearly demonstrated. Legal and regulatory battles of this magnitude are extremely expensive, and this is where you can help.
Our legal research and official comments are due to CMS by mid-December, and the necessary work has to start now, so time is of the essence.
How you can help
Simple, donate. In the past, SVU and other specialty organizations joined together to fund legal efforts to mitigate reimbursement reductions; however, since these cuts do not affect the radiology and cardiology ultrasound codes nearly as much as ours, it is less likely that other specialty organizations will join SVU in this battle. SVU will most likely be funding this fight alone so we encourage all members to contribute to the SVU Advocacy Fund to defray the cost of this effort. This change affects you; take action to protect your job and your future. SVU has over 5,000 members. We can pull together and show our commitment to our field by donating today. If every member gave just $10 and encouraged their employers, physicians, friends and sales representatives to contribute, SVU would be able to fund the immediate efforts necessary.
This is an urgent issue for our field, with potentially dire consequences. We as SVU members could do nothing and live with the consequences of these cuts, or we can band together as an organization to assure continued viability as a profession. We’ve done it before and we can do it again.