New TAVR NCD Published
Last week, the Centers for Medicare & Medicaid Services (CMS) published a new national coverage determination (NCD) for transcatheter aortic valve replacement (TAVR) that represents a yearlong effort to update the existing terms of Medicare coverage. The new NCD changes minimum procedure volume requirements to open and maintain a TAVR program and establishes new research questions for coverage with evidence development utilizing data from the STS/ACC TVT RegistryTM. Also, the decision no longer requires that two surgeons evaluate the patient prior to TAVR, but instead promotes a heart team approach, stating that a surgeon and an interventional cardiologist each must examine the patient. Earlier in the month, STS joined the American College of Cardiology (ACC), the American Association for Thoracic Surgery (AATS), and the Society for Cardiovascular Angiography & Interventions (SCAI) in reiterating support for this heart team approach after Congress sent a letter to CMS questioning the policy. More information on the TAVR NCD will be included in next week’s issue of STS News.
Societies Request Review of TMVR Medicare Coverage
STS, ACC, AATS, and SCAI also have requested that CMS reconsider the current transcatheter mitral valve repair (TMVR) NCD. This appeal was driven by new scientific evidence showing that TMVR is beneficial to patients with secondary or functional mitral regurgitation and the corresponding approval of this new patient indication by the Food & Drug Administration. CMS responded and stated that the agency will look at the NCD in the future; STS will provide updates as discussions progress.
CMS Adjusts Malpractice RVUs for Certain Procedures
CMS has corrected a series of low-volume cardiothoracic surgery procedure codes related to Professional Liability Insurance (PLI) Relative Value Units (RVUs). The changes take effect July 1 but are retroactive to January 1, 2019—meaning that, if applicable, you can resubmit claims for these services to be reprocessed and receive the updated Medicare reimbursement. This table provides a list of cardiothoracic surgery codes with the corrected PLI values. Please keep in mind that the table includes only the PLI values; it does not include the work, practice expense, or total RVUs.
STS Takes Action on ECMO Payments, Data Access, MACRA Implementation, Rehab Care Quality
The Society is working with national medical societies, public health groups, and research organizations on the following issues affecting cardiothoracic surgeons and their patients:
- ECMO Payments—STS commented on several aspects of the Fiscal Year 2020 Medicare Inpatient Prospective Payment System Proposed Rule, including the proposal to reinstate original reimbursement levels for extracorporeal membrane oxygenation (ECMO) procedures—a goal achieved after months of lobbying by STS, the Extracorporeal Life Support Organization, and other stakeholders. The comment letter applauded this development, but noted that the proposed rule still erroneously conflates peripheral and percutaneous approaches for ECMO cannulation.
- Interoperability and Data Blocking—The Society sent feedback to the Office of the National Coordinator for Health Information Technology regarding the Interoperability and Information Blocking Proposed Rule. STS supported increasing patient access to their personal health data, but also encouraged greater physician access to clinical data for care improvement. STS also signed a Registry Coalition letter regarding the proposed rule.
- MACRA Implementation—A coalition letter sent to Congressional leaders emphasized the need for further refinements to implementation of the Medicare Access and CHIP Reauthorization Act, including positive payment adjustments for physicians that will replace the 6-year pay freeze stipulated in the statute, an extension of Advanced Alternative Payment Model bonus payments for an additional 6 years, and technical adjustments that will increase flexibility in scoring and reduce silos in the Merit-Based Incentive Payment System.
- Rehabilitation Physician Certification—A new policy included in the Fiscal Year 2020 Inpatient Rehabilitation Facility Proposed Rule would loosen requirements for qualification as a “rehabilitation physician.” STS signed a coalition letter to CMS expressing concern that this lack of specific standards could result in suboptimal patient care.