Hundreds of Ophthalmologists Speak Up Against CMS’ Fee Schedule Cuts

Ophthalmology’s campaign to fight back against the Centers for Medicare & Medicaid Services’ 2016 fee schedule netted hundreds of comments from angry Academy members just as the agency’s comment period closed. More than 300 hundred Academy members spoke out. Their comments mirrored the Academy’s formal response to the agency, in which we lashed out at CMS’ “draconian” reductions to payments for glaucoma, retina and lacrimal procedures. We are using this significant momentum to wrangle additional support within Congress and the physician community.

The Academy, along with the American Glaucoma Society, the Retina Society and the American Society of Retina Specialists, have repeatedly expressed to CMS that the agency broke statutory resource-based relative value scale requirements when it ignored intensity and complexity in its valuations. Those two factors were at the core of the AMA/Specialty Society Relative Value Scale Update Committee’s recommendations, which suggested some appropriate fee adjustments. Unfortunately, these recommendations were ignored by CMS, which opted for deeper cuts.

We are also calling on CMS to show the legal justification for its decision to solely consider time in determining payment value. This is a significant departure from past fee decisions.

Academy comment highlights

• CMS interim values at issue are not consistent with the resource-based relative value scale methodology. This raises policy and process concerns. 
• CMS should have a discussion with the RUC at the committee’s April meeting regarding this significant change in methodology. 
• The Academy requests that CMS provide transparency by sharing its legal review of a solely time-based approach. As part this, we feel that the agency must also share the statutory authority that demonstrates that such a significant change in methodology is appropriate. 
• CMS gave physicians little time to prepare for such draconian cuts. This is unprecedented and unfair the entire physician community because of such a short window for action. 
• We strongly recommend that CMS not move forward with interim final values. Instead, it should adopt the work relative value units recommended by the RUC. This would maintain the integrity of the resource-based relative value scale.