Dear Administrator Tavenner,
We are writing to express our concern regarding the provision contained in Centers for Medicare
and Medicaid Services’ (CMS) Physician Fee Schedule (PFS) proposed rule for calendar year
(CY) 2015 to convert all 10- and 90-day global procedures to 0-day global procedures beginning
in 2017.
We urge CMS not to finalize this proposal in the 2015 Physician Fee Schedule Final Rule and,
instead, work with the surgical community and Congress on ways to address the concerns
articulated in the proposed rule.
We believe that disrupting global surgical payments will be detrimental to beneficiary care,
increase administrative burdens, and hinder the ongoing, systematic efforts to improve and
coordinate the delivery of quality health care.
Global payments incentivize providers to coordinate care. We believe that supporting a
coordinated, team approach to healthcare is the best way to ensure that patients receive the
highest quality, and most efficient care. Without the global payment, we are concerned that
surgeons will lose the ability to coordinate postoperative care for critically ill patients. Patients
may also be less inclined to attend their follow-up appointments as a result of additional co-pays
for each visit.
In addition to compromising individual patient care, eliminating the surgical global payment will
limit the collection of patient outcomes information if patients elect to forgo follow-up or seek
treatment from other health care providers. Obstructing the use of clinical data registries is a
significant setback in the progress that has been made in disease tracking and quality
improvement.
Further, current bipartisan, bicameral legislation to repeal and replace the flawed sustainable
growth rate formula calls for a “period of stability” in physician pay to allow physicians to
transition to alternative payment models. This proposal intends to introduce new complexities
into an already flawed system and stymie that progress.
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