I have copied the letter submitted to Congress by the CEO of the American Academy of Otolaryngology and Head and Neck Surgeons on behalf of their membership which includes approximately 92% of all practicing ENT surgeons in the country. Similar letters have been submitted by other medical specialist organizations. It provides great insight into what is needed and why with respect to Medicare Reform. If we want quality healthcare in the future, getting reform right will depend on involving physicians in the process. Make sure reform isn't crafted solely by politicians and bureaucrats. Your health depends on it!
April 27, 2011
John O’Shea, MD
U.S. House of Representatives
2125 Rayburn House Office Building
Washington, DC 20515
U.S. House of Representatives
237 Cannon House Office Building
Washington, DC 20515
Dear Mr. Gronniger:
J. Timothy Gronniger U.S House of Representatives 2322A Rayburn House Office Building Washington, DC 20515
On behalf of the 12,000 members of the American Academy of Otolaryngology–Head and Neck Surgery (AAO-HNS), I appreciate the opportunity to provide input regarding the concurrent efforts to permanently repeal the flawed Sustainable Growth Rate (SGR) formula and develop a new Medicare physician payment system that will provide necessary stability for physicians and ensure access to quality care for the nation’s senior population.
The AAO-HNS is the national medical association of physicians dedicated to the care of patients with disorders of the ears, nose, throat (ENT), and related structures of the head and neck. We are commonly referred to as ENT surgeons.
The existing Medicare physician payment system, driven by the SGR formula, is broken beyond repair. For years, physicians across the House of Medicine have struggled in a system that fails to differentiate by provider or specialty and lacks the tools necessary for recognizing quality and/or efficiency in regards to the delivery of care. The strict budgetary focus and inherent instability of the current payment system have resulted in large negative annual updates that threaten providers’ willingness and ability to care for beneficiaries. In addition, it has become increasingly difficult for physicians to make fiscally responsible, and necessary, practice management decisions. Because of these and other contributing factors, the AAO-HNS strongly believes that no more time should be wasted on efforts to mend the current system.
Eliminating the SGR is the cornerstone to an evolved payment system that improves quality, lowers costs, and better integrates the delivery of care across all patient care settings. Moving forward, any new payment model must, by design, include mechanisms to better inform policy- makers of spending growth trends, while simultaneously facilitating appropriate expenditure controls. Modern-day healthcare is dynamic and any payment mechanism should reflect the ongoing evolution of care.
More specifically, using a target growth rate system by carving out a small number of service categories may help to track and correct for volume growth (service categories growth rate, SCGR). Two categories of service types that could be used for this payment model are evaluation and management codes (E&M), and all others. This would provide physicians with the autonomy to provide care that addresses each patient’s unique medical needs.
The AAO-HNS also wants to emphasize the importance of maintaining the current AMA Relative Value Update Committee (RUC) to value current physician services and those that may be bundled together in the future. We encourage you to continue to rely upon its expertise in
valuing MFFS physician services. The key strength of the RUC is that it is convened by and comprised of physicians, with additional representation by non-physician healthcare practitioners. No other entity has the expertise to determine the appropriate complexity, intensity, and associated risk of a procedure than the collective, deliberative panel of the RUC.
While it is of paramount importance to develop and implement an updated physician payment mechanism, we urge Congress to refrain from viewing the problems associated with physician payment in a “vacuum.” Payment reforms impacting other healthcare providers should be considered and may be necessary to ensure a fair, stable Medicare system emerges from your efforts. In addition, recent reforms very much support tying compensation to outcomes and quality. The ability of physicians to meet many of the tenets of Meaningful Use and the requirements for Accountable Care Organizations (ACOs) will obviously affect physician reimbursement, and therefore should be considered in your deliberations regarding physician payment reform. Unfortunately, it may be too early to determine how these programs will fully impact the delivery of care.
Further, the notion of “healthcare reform” must also extend to beneficiaries. Attempts must be made to better educate patients/beneficiaries about the costs associated with healthcare services and resources. Without increased patient education and accountability, a large piece of the healthcare reform puzzle will be missing.
In the next few months, the AAO-HNS looks forward to working with Congress to build upon last year’s bipartisan effort to permanently replace the SGR formula with a workable system that rewards quality and efficiency, while still keeping pace with rising practice costs. And, to help demonstrate our commitment to ensuring patients have access to the highest quality healthcare available, we recently convened an Advisory Council on Quality. This Council is comprised of internal and external subject matter experts to provide expertise to the AAO-HNS quality agenda, including the development of a specialty-specific data registry. We will keep Congress apprised of this new initiative and any impact it may have on your future discussions.
Again, thank you for the opportunity to provide input on your efforts to permanently reform the Medicare physician payment system. This will undoubtedly be a daunting, yet necessary, undertaking, but the AAO-HNS and others in the physician community stand ready to assist in any way possible. If you have questions regarding the AAO-HNS positions stated above, please contact Megan Marcinko, Senior Manager for Congressional and Political Affairs, at 703-535- 3796 or firstname.lastname@example.org.
David R. Nielsen, MD Executive Vice President and CEO