TEMPLATE LETTER TO CMS ACTING ADMINISTRATOR SLAVITT
Dear Acting Administrator Slavitt:
As a practicing gastroenterologist, I write to express my serious concerns about proposed reimbursement rates in the calendar year (CY) 2016 Medicare Physician Fee Schedule Proposed Rule. While I appreciate the steps taken by CMS to allow meaningful participation in the new transparent fee setting process, the provisions put forth for CY2016 pose a major threat to Medicare beneficiaries.
I urge you to reconsider the dramatic cuts to colonoscopy contained in the proposed rule so that necessary screening and treatment for critical diseases and cancer are not compromised. There are two critical issues at stake: a threat to public health progress in the fight against colorectal cancer and a practice management challenge for gastroenterologists who serve Medicare patients.
Gastroenterologists across the country share a longstanding commitment to enhance the detection and treatment of colorectal cancer. Aided by public health and outreach efforts, we are making great strides toward reducing the incidence and mortality of this disease, yet it remains the second leading cause of cancer death in the United States. Physicians and other stakeholders are dedicated to working toward achieving 80 percent screened by 2018, a goal supported by the U.S. Department of Health and Human Services and the Centers for Disease Control and Prevention. It is especially disheartening to know that CMS is considering steps that will hinder this valuable effort at a time when our nation is seeing measurable advances against colorectal cancer thanks to screening and polypectomy.
The proposed reimbursement cuts threaten the cancer screening progress that we have made. Because of the economic realities of running a medical practice in 2015, Medicare beneficiaries throughout the U.S. will likely encounter restricted access to vital screening services as a consequence of planned cuts. The serious public health impacts of this change will manifest only after the damage has already occurred. According to a poll of more than 550 gastroenterologists, more than half of the respondents plan to limit new Medicare patients if the proposed cuts are implemented; 55 percent plan to limit procedures to Medicare patients; and 15 percent are considering opting out of Medicare entirely. These findings suggest that GI physicians may not be able to maintain the current mix of Medicare patients and protect the financial viability of their practices.
I am further concerned with the arbitrary and faulty means that CMS used to develop the rates. The GI and surgical societies spent significant time surveying physicians to determine resources and work times for colonoscopy that reflect the care and diligence involved with increasingly complicated screenings. Unfortunately, CMS chose to ignore the robust and scientifically valid data derived from these studies. Instead, the proposed rates rely on a set of flawed recommendations that did not consider the survey results, which are the most reliable indicator of the work involved in colonoscopy. The proposed cuts involve an unprecedented number of GI codes being revalued at once, with entire families of codes experiencing significant cuts. This could have a great impact on practice operations.
I urge you to listen to gastroenterologists throughout the country when we say the cuts to colonoscopy will set us back years of screening progress. If adopted, the provisions of the proposed rule will undermine our collective efforts and diminish our common achievements in reducing deaths and suffering from colorectal cancer.
The short-sighted and unjustified cuts to Medicare reimbursement for colonoscopy come at the point when CMS should be working to build on the real progress we have made in expanding access to critical screening efforts. CMS should abandon these proposed changes and take steps to provide Medicare beneficiaries with more, not less, access to screening and prevention services.
I thank you for your consideration.
Sincerely,
[YOUR NAME]
[Practice Name]
[Practice Location]