ASIPP Supports Positive Impact of CMS Proposed Rule Implementation for Physicians

Once Centers for Medicare & Medicaid Services (CMS) 2019 Medicare Physician Fee Schedule Proposed Rule is implemented, it will improve access to interventional pain management services and also reduce paperwork and the stress levels with improvement in physician-patient interaction. On September 10, 2018, ASIPP submitted its comments on the proposed rule with strong support for evaluation and management services and a strong request to alter payments for office procedures, specifically peripheral nerve blocks and neurolytic blocks with comments on quality payment program.

Changes of payment mode for evaluation and management, similar to United Kingdom, with one payment for most levels of services, as proposed by CMS, avoids multiple issues of upcoding, downcoding, reduces documentation difficulties, improves patient interaction, reduces physician stress, and, finally, even increases reimbursement levels for physicians.

Almost all physicians will be affected positively. The only physicians who will be affected negatively include those who use Level 4 and 5 codes extensively.
We have received extensive support from the board and membership

Dr. Manchikati stated:
"If a physician is using 50% of the time, Level 2 or 3 codes, and 50% of the time Level 4 codes, there will be some benefit. However, if a physician is using Level 2 and 3 codes 75% of the time and Level 4 and 5 codes only 25% of the time, they will benefit significantly. I understand that multiple organizations are voicing their complaints about the collapsing of the codes; however, for interventional pain physicians we will see a small increase, but at the same time, major benefit is reduced stress levels, reduced documentation requirements and increased patient/physician interaction time. But, the only negative aspect is that if a procedure is performed on the same day as evaluation and management service, one of the services will face 50% reduction which is a major disadvantage, which happens very infrequently.”

Dr. Manchikanti also noted that we asked CMS to reassess the office based payments since these are only a fraction of hospital payments. The specific procedures quoted were peripheral nerve blocks and neurolytic blocks which are reimbursed at almost 1,800% higher than in office for peripheral nerve blocks and neurolytic blocks. CMS and RUC should be reassessing these issues and we request that our RUC membership negotiate with AMA to re-evaluate these payment levels.


Click HERE to read ASIPP's comment letter to CMS