The American College of Cardiology (ACC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Sept. 6 regarding the Hospital Outpatient Prospective Payment System (OPPS) for 2017.

In a letter addressed to acting CMS administrator Andrew M. Slavitt, ACC president Richard A. Chazal, MD, FACC, expressed concern that the proposed imaging ambulatory payment classification structure for calendar year 2017 “does not accurately capture classifications of cardiovascular imaging services based on clinical and resource homogeneity.”

The ACC also requested a cautious approach when implementing Section 603 of the Bipartisan Budget Act of 2015 and modifications to the electronic health record (EHR) incentive program reporting period for 2016.

The ACC mentioned in the letter that the number of imaging ambulatory payment classifications decreased from 54 in 2015 to 19 in 2016. CMS has proposed reducing the number to 10 in 2017, but the ACC would like it to remain at 19 for next year.

“The constant changes to the [ambulatory payment classification] structure have made it difficult for the [ACC] to understand the impact of these policies and recommend stable long-term placements for cardiovascular imaging services,” Chazal wrote. “While the [ACC] agrees with the goal of improving clinical and resource homogeneity, further improvements cannot be made until stakeholders have at least two years of data from the [calendar year] 2016 changes and a clear understanding of CMS’s rationale.”

The ACC also said that CMS was overly restrictive with its interpretation of off-campus provider-based departments (PBDs) excepted from proposed policies in Section 603 of the Bipartisan Budget Act of 2015.

“CMS proposes to permit relocation only in certain circumstances such as a natural disaster or to meet federal or state requirements,” Chazal wrote. “The ACC believes that this proposal goes beyond what Congress intended through Section 603. CMS should be concerned with off-campus PBDs that expand, but limiting the ability to move within the same building is excessively restrictive. 
CMS proposes that exempted off-campus PBDs would only be permitted to bill under the OPPS for services from a clinical family of services that were furnished prior to November 2, 2015.”

In addition, the ACC said it was concerned with the CMS proposal to pay off-campus PBDs at the Medicare Physician Fee Schedule rate next year. The ACC recommended that the PBDs enroll as an alternative provider or supplier type and be paid under the appropriate system.

The ACC also suggested that CMS reduce the EHR incentive program reporting period from a calendar year to 90 days, establish modified stage 2 criteria for new program participants and implement a blanket hardship exception from the 2018 payment adjustment for new participants in the EHR incentive program who will be transitioning to the Merit-Based Incentive Payment System.

“The ACC appreciates CMS’s consideration of the comments provided in this letter,” Chazal wrote. “We encourage the Agency to continue to work closely with stakeholders to ensure that new policies support the mission to provide high-quality cardiovascular care to Medicare beneficiaries. We also urge CMS to consider the impact that the transition to value-based payment is having on clinicians and to ensure that any policies implemented in the OPPS are in alignment with this broader goal and do not create additional administrative burden or interference with clinical workflow.”