ACP–ASIM is opposing HCFA's decision to reduce work relative value units (RVUs) for critical care services.
While both the Relative Value Scale Update Committee panel and the AMA advised against any changes in work RVUs for critical care codes 99291 and 99292 for calendar year 2000, HCFA reduced the values by 10%. The agency said it lowered the work RVUs because it anticipates an increasing amount of services will be billed as critical care.
In a Dec. 29 letter to HCFA Administrator Nancy-Ann DeParle, Cecil B. Wilson, FACP, Chair of the College's Medical Services Committee, urged HCFA to restore the initial values for the critical care codes at 4.00 RVUs for 99291 and 2.00 RVUs for 99292. He also argued that RVUs for all codes should be based on data related to the work performed, not on anticipated shifts in utilization. He said that HCFA should account for predicted shifts in utilization through other means, not RVUs.
In his letter, Dr. Wilson also noted that the College is concerned about several other changes in the Medicare physician fee schedule, which was published in November.
•Nine new HCPCS Level 2 or "G" codes have been added to the physician fee schedule to describe procedural services. While HCFA has said that these codes are temporary and will be submitted to the Current Procedural Terminology Editorial Panel, ACP–ASIM strongly recommended that all codes be submitted to the editorial panel before they are adopted.
•HCFA has "weakened" its regulations allowing nurse practitioners to bill separately under Medicare because it has not adequately defined legal issues regarding physician/nurse collaborations. Dr. Wilson said that HCFA must define in its regulations terms like "scope of practice" and "collaboration" for nurse practitioners to better define its billing parameters.
HCFA's appeals process gets mixed review
HCFA's efforts to allow physicians and suppliers to appeal when Medicare carriers deny their enrollment applications is a step in the right direction, but ACP–ASIM says that more changes are necessary.
Currently, physicians and suppliers have no right to appeal denials by Medicare carriers. While the College supports HCFA's latest efforts to change that situation, it says that the agency's current proposal places too much of a burden on physicians.
In a Dec. 27 letter to HCFA Administrator Nancy-Ann DeParle, the College urged HCFA to require carriers to offer an explanation when physicians' enrollment applications are disallowed or their billing numbers are revoked. HCFA's proposal currently would put the burden of proof on physicians to show that an enrollment application was incorrectly disallowed. ACP–ASIM characterized that provision as "inappropriate" and said that Medicare carriers should have to provide a reason for denying or revoking a physician's enrollment. At the very least, the College said, carriers should have to justify their decisions before their own hearing boards.
ACP–ASIM is also urging HCFA to require carriers to process applications for billing privileges in a timely manner. The College would also like carriers to allow physicians to use temporary billing numbers until permanent billing numbers can be assigned.
Compiled by Janice Simmons, a Washington writer specializing in health care.
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