July 18, 2012
Update on the Issues: ASIPP Receives HHS Response
The Good, the Bad, and the Ugly
As you may recall, ASIPP started the process of fighting several current and impending regulatory burdens on November 18, 2011, when we sent a letter to HHS Secretary, Kathleen Sebelius, addressing our concern over the single-dose vial policy, the implementation of ICD-10, and EMR Regulations. After a long delay, we have finally received a response on July 12. We'd like to share their response and update you on these issues.
The good news is our letters and calls are working. CMS seems to be listening and they have agreed to delay the implementation of ICD-10 until Oct. 1, 2014. While we will continue to aggressively work to stop the implementation of ICD-10, the delay is a positive turn, and will also buy time to work on this issue.
Read ASIPP's letter to Kathleen Sebelius and the HHS response.
Single Dose Vial Policy
As you well know, from our recent updates, things may be improving slightly, but not significantly in regard to the single-dose vial policy. Recently, CMS has published repackaging regulations that now allow for multidose vials to be divided by compounding pharmacies (Safe Use of Single Dose/Single Use Medications to Prevent Healthcare-associated Infections
While this new regulation my help the expense somewhat, it is tedious and unnecessary, and there are more cases of infections and increased risk with compounding, rather than dividing the single doses into multiple doses in an office or surgery center.
In addition to this, the CDC has recently published 2 case reports in an effort to show that single dose vial use was responsible. Out of the 2 cases, only one case was related to interventional pain management. Unfortunately in this one case there are many unanswered questions. We are not aware of all the details such as whether the 10 ml was obtained from a compounding pharmacy or directly from the manufacturer. If a compounding pharmacy was used, that might explain some of the issues presented. Nor does the report describe the sterile procedures, etc. or how MRSA could get into single dose vials. Lastly, the report fails to explain the nature and sterility of the bottles.
The second case relates to an orthopedic surgeon in a hospital setting with infections developing from oral flora for not wearing a mask. While there is a clear-cut explanation there, it is not the single dose vial, but rather the compromised sterile technique.
As expected, the HHS provides no encouragement on the EMR issue. It does not address our concerns over the burdens of the evolving regulations and escalating costs this creates for all physicians.
Unbelievable but Great News: House Puts AHRQ on Chopping Block
The House of Representatives has drafted an appropriations bill that will dissolve the AHRQ and prohibit any funding for patient-centered outcomes research (PCOR). The AHRQ is an agency that spearheads and funds healthcare safety and quality research, as well as ways to rein in the costs while expanding access.
Advocates for medical research and health care quality improvement assailed a proposal by House appropriators to get rid of the Agency for Healthcare Research and Quality - a move that could come to a head during a markup of the Labor-HHS funding package this morning.
The bill states that the agency would be "terminated" effective Oct. 1, 2012. It would rescind all funds that haven't been spent yet, and would transfer activities that fall under the agency.
Click HERE to read the House press bill on the House appropriations bill to terminate AHRQ and prohibit funding patient-centered research
Click HERE to read draft of bill.
Update on the CRNA Scope of Practice Issue: Time to Act is NOW!
ASIPP is working diligently to try to get the CRNA Scope of Practie ruling resolved.
Here are links to 3 documents - a letter sent to Kathleen Sebeliuson June 28, 2012, a document prepared by David Vaughn of Vaughn & Associates which illustrates the issues related to this, and an article from Outpatient Surgery.
1.CMS has failed to perform cost analysis yet that states that there is no change in the cost but they do state that it would improve access, based only on the statement from AANA, which is quite inappropriate for a governmental agency.
2. Surveys from OIG of CMS have shown a rise in fraud and abuse issues related to interventional pain management, which can be traced back to untrained physicians and other health practitioners, including nurse anesthetists no providing pain management techniques.
3. The opioid epidemic is becoming more and more common. The evaluations show that
prescriptions written by nurse practitioners, PAs, and nurse anesthetists are increasing.
4. Louisiana State Supreme Court ruled that IPM is a practice of medicine and that CRNAs should
not be practicing interventional pain management. Other states have imposed many restrictions. In
fact, in Tennessee, no physicians other than anesthesiologists, physiatrists, and neurologists can
perform these procedures unless they have fellowship training.
Today the percent of anesthesiologists providing IPMis only 60%.
We will be following up on this issue shortly with ways for you to voice your concerns on this issue.
Physician Quality Reporting System Webinar Tomorrow
Join us Thursday, July 19 from 130 to 3 pm for a webinar hosted by Marvel Hammer, RN, CPC, on the Physician Quality Reporting System (PQRS). Registration fee is $175.
PQRS is a reporting program that uses a combination of incentive payments and payment adjustments to promote reporting of quality information by eligible professionals. The program provides an incentive payment to practices with eligible professionals (identified on claims by their individual National Provider Identifier [NPI] and Tax Identification Number [TIN]) who satisfactorily report data on quality measures for covered Physician Fee Schedule (PFS) services furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (including Railroad Retirement Board and Medicare Secondary Payer). PQRS is mandated by federal legislation.
2012 should be considered the practice year if you aren't already successfully reporting PQRS measures to Medicare.
The CMS 2012 Medicare Physician Fee Schedule notes that 2015 program penalties will be based on 2013 performance. Consequently, those physicians who elect not to participate or are found unsuccessful during the 2013 program year, will receive a 1.5% payment penalty, and 2% thereafter.
These PQRS penalties will be above and beyond the e-Rx penalties. Unlike e-Rx, currently there are no established hardship exemptions for PQRS. Unlike e-Rx, practices are still eligible for the 2012 PQRS Incentive if they are participating with the Medicare EMR Meaningful Use program.
The webinar will cover:
- What Medicare changes have been enacted for 2012?
- What measures are available and best for my
Interventional Pain Management practice?
- What are the 2012 options for reporting PQRS?
- Is it too late to start reporting PQRS for 2012?
- What is an outcome measurement tool?
- Know if you can earn Physician Quality Reporting incentive payments.
- Show you how to participate in the Physician Quality Reporting System
Registration and other information can be found at:
Few Spots Remain: Still Time to Register for San Francisco Board Review Course
ASIPP's comprehensive board review course is set for July 30 to Aug. 3 in San Francisco.
This intensive and comprehensive high-quality review is geared to prepare physicians appearing for the American Board of Medical Specialties (ABMS)-Subspecialty Pain Medicine examination and for the American Board of Interventional Pain Physicians (ABIPP)-Part 1 examination.
- A five-day review covering anatomy, physiology, pharmacology, psychology,
ethics, interventional techniques, non-interventional techniques,
controlled substances and practice management
- 39 unique lectures by experts in the field
- Participants can earn up to 44.25 AMA PRA Category 1 Credits
The course will be held The Westin San Francisco Market Street.
Click HEREfor brochure.
Click HERE to register.
Still Time to Register to Attend Review Courses, Competency Exams in San Francisco
Attend the Comprehensive Review Course in Controlled Substance Management July 30-31 and take that Competency Exam on Aug. 1
Click HERE to see Brochure.
Attend the Comprehensive Review Course in Coding, Compliance and Practice Management Aug. 2-3 and take that competency exam Aug.5.
Click HERE to see brochure.
Click HEREfor hotel reservations.
Medicare Previews Pay Increases and Cuts for 2013
Washington The Medicare program would pay doctors to coordinate patient care following a discharge from a hospital starting in 2013, according to a proposal from the Centers for Medicare & Medicaid Services.
The service would include payments for phone calls and other related care management activities that currently are not compensated, the Medicare agency stated in its proposed 2013 physician fee schedule, released July 6. If adopted, the provision would mark the first time CMS covered a physician service specifically designed to help patients transition from a hospital or nursing facility setting and to pilot their care as they move back into the community.
Congress Wants Medicare Auditors to Face their Own Review
Washington A bipartisan group of lawmakers is questioning the role auditing contractors should play in the Medicare program, saying the audits place burdensome requirements on physicians and hospitals.
Five senators and six House lawmakers called on the Government Accountability Office to review contracted Medicare auditors, which include Medicare administrative contractors, recovery audit contractors and program safeguard contractors. The GAO should study the coordination of audits and contractor interactions with physicians and hospitals, the lawmakers wrote in a June 26 letter.
"Health care providers are responsible for interacting with, and responding to, these contractors," the letter stated. "In order for this contractor oversight to at once be effective at detecting improper payments and not unnecessarily burdensome to providers, it must be undertaken subject to a coherent strategic plan, consistent standards and active coordination."
Maine's Medicaid Showdown with HHS
In what is shaping up as the first state-federal showdown on Medicaid following the Supreme Court's ruling on President Barack Obama's health law, Maine is moving ahead with plans to cut about 38,000 people from its rolls to balance its state budget.
Advocates and health experts contend that would violate a provision of the law barring states from making it harder for people to join the government health insurance program for the poor.
Among those who would lose health care coverage as early as September are nearly 15,000 Maine parents with incomes between the federal poverty level ($23,050 for a family of four) and 133 percent of the poverty level ($30,657), as well as 6,000 19- and 20-year-olds who have been covered up to 150 percent of the poverty level ($34,575 for a family of four).
Healthcare Finance News
Abuse-Proof Prescription Painkillers May Spur Heroin Habit
The move by drug companies to make abuse-proof prescription painkillers may be inadvertently promoting heroin use, a new study found.
The study of more than 2,500 people with opioid dependence found a 17 percent drop in OxyContin abuse with the 2010 arrival of a formula that's harder to inhale or inject. During the same time period, heroin abuse doubled.
OxyContin Abuse Down with Time-Release Formula
There's more evidence that the new formulation of OxyContin, the time-release version of oxycodone, is discouraging abuse of the powerful drug.
But the reformulation, introduced in August 2010 to make it harder to crush the medicine into powder, limiting the ability to snort, inject or smoke it, may be causing other problems, researchers warn.
Interviewed recently, only about 13 percent of addicts with an opioid dependence said it was their primary drug of abuse, compared to about 36 percent prior to the new version hitting the shelves.
A Better Health Insurance System
American families need better options for health insurance. A health insurance system needs to be accessible, portable and inexpensive, just like other forms of insurance. In contrast, the Affordable Care Act (ACA) mandates a one-size-fits all, overly-generous plan that, combined with the requirement that people can sign up anytime, will prove to be very expensive, says Diana Furchtgott-Roth, a senior fellow at the Manhattan Institute.
There's no reason that America's economy can't produce more health insurance choices. The economy provides a wide range of insurance products -- home insurance, auto insurance, life insurance, renters' insurance -- which Americans choose to buy without mandates. The health care insurance industry can produce the same options if government can be an enabler rather than a provider.
The following are the tenants of a fully functional, market-based approach to health insurance. It entails individuals purchasing their own plans and cutting employers-as-middlemen out of the picture.
- The federal government should provide tax credits for the purchase of health insurance, and it should counterbalance this policy by removing the current tax favoritism given to insurance provided by employers.
- This would allow for a functional market in which health insurance providers court potential customers just as insurers in other fields do.
- Further, the amount of the credit could be adjusted up or down depending on income.
- Additionally, insurance providers should be allowed to operate over state lines, thereby overcoming the current fractionalization of the national health insurance market.
- In order to provide for the 2 million to 4 million people with uninsurable conditions, states should create risk pools for special insurance, supported by the federal government.
- This concentration and direct support will be much cheaper and more easily managed than the behemoth bureaucracy that the ACA would create.
Medicaid Freedom of Choice
The Medicaid system, which provides health care to many of America's most in need, is largely broken. Its problems, broadly, fall into two categories. First, it creates subpar health outcomes for enrollees who, because of their lack of economic means, often have no alternative avenue to gain care. Second, it creates unnecessary cost overruns due to poorly conceived incentives, say Stephen Moore, a member of the Wall Street Journal editorial board, and Peter Ferrara, a senior fellow at the National Center for Policy Analysis.
With regard to the first problem, numerous studies have been conducted that show that, for a number of reasons, Medicaid participants routinely receive poor treatment by health care providers.
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American Society of Interventional Pain Physicians ®
81 Lakeview Drive, Paducah, KY 42001
Phone 270.554.9412, Fax 270.554.5394