Last week we reported that the College and Academy leadership had met with the Centers for Medicare and Medicaid Services (CMS). We also recently sent this letter, in cooperation with the AAAAI and the AAOA, to CMS Administrator Seema Verma expressing specific concerns for the allergy/immunology specialty on the recent Proposed Rule revising the Physician Payment Schedule for 2019. We focused on four issues:
- The cost of venom antigens used in treating stinging insect allergies.
- The proposal to reduce the supply cost for inhalant antigens used in allergen immunotherapy.
- The proposed change in the allergy/immunology indirect practice cost index resulting from the consolidation of E&M office visit codes and the creations of a separate “specialty” for E&M office visits.
- The multiple procedure payment reduction policy.
We specifically asked that:
- The cost input for 1cc (1ml) single venom 3-vespid mix antigens be increased accounting for recent extract price increases to take effect January 1, 2019.
- CMS implement the higher direct cost input determined by their consultant. In the alternative, CMS should maintain the current input and not implement any reductions.
- CMS delay its implementation of E&M simplification and work with the American Medical Association and medical specialty societies to develop a better and less destabilizing approach to E&M.
We’re still fighting for fair reimbursement for the work that you do – and the College's Advocacy Council will keep you updated on any new developments as they happen.