Society of Thoracic Surgeons Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, Sept. 28 -- Joseph A. Dearani, president of the Society of Thoracic Surgeons, has issued a public comment on the Centers for Medicare and Medicaid Services proposed rule entitled "Medicare Program: CY 2021 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; etc.". The comment was written and posted on Sept. 23, 2020:

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On behalf of The Society of Thoracic Surgeons (STS), I write to provide comments on the Fiscal Year (FY) 2021 Physician Fee Schedule (PFS) Proposed Rule. Founded in 1964, The Society of Thoracic Surgeons is a not-for-profit organization representing more than 7,500 surgeons, researchers, and allied health care professionals worldwide who are dedicated to ensuring the best possible outcomes for surgeries of the heart, lungs, and esophagus, as well as other surgical procedures within the chest.

The below comments address the following sections of the PFS Proposed Rule:

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General Comments

We are deeply concerned that the proposed sharp cuts to reimbursement will amplify the financial instability practices are already experiencing due to the COVID-19 pandemic. The pandemic caused delays in care and sharply reduced patient care volumes that in many cases led to difficult but unavoidable financial decisions, including reduced staffing. Delayed care has also exacerbated many patient conditions that will now require even more specialized treatment. As patient care slowly becomes more possible during and after the pandemic, many practices and health care systems that depend on procedures to regain financial stability and reestablish pre-pandemic staffing levels will instead be hit by another financial crisis in January: substantial cuts to Medicare payments for professional services.

CMS proposes in this rule to drastically reduce payment across the majority of specialties primarily due to the roll-out of Evaluation and Management (E/M) codes representing more complex care and greater physician work even as these specialties have actively contributed to both patient COVID-19 treatment and health system financial recovery.

Although cardiothoracic surgery is one among many specialties negatively impacted by these cuts, we are specifically concerned with the impact 9% and 8% cuts will have to patient access to cardiac and thoracic surgery, respectively. Especially in the Medicare population, cardiac and thoracic surgery is often critical to beneficiaries' health outcomes. At 25% of all cancer deaths, lung cancer is the leading cause of cancer death in the U.S. and worldwide--it is estimated over 135,000 lung cancer deaths will occur in 2020 in the United States./1

The Medicare population shoulders the majority of this disease burden--the average age of people diagnosed is 70./2

Heart disease is the leading cause of death in the United States and accounts for 1 in every 4 deaths./3

Cardiothoracic surgeons have also played a key role in treating COVID-19 patients who have not responded to standard treatments. When other treatments, including ventilator support, fail to improve a patient's respiratory function, cardiothoracic surgeons may use extracorporeal membrane oxygenation (ECMO), a treatment which re-oxygenates the blood, and in select cases lung transplantation.

Cardiothoracic surgery practices facing financial hardship due to the combined effect of the pandemic and the Medicare cuts will unfortunately face tough choices to remain financially viable. These choices will likely impact patient access to care, staffing levels, investment in new treatment technology, surgeon training, and clinical research of new treatments. These impacts will unfortunately be felt most acutely among underserved populations and geographic areas that already face financial hardship and care shortages.

Even without consideration of the COVID-19 pandemic, the proposed cuts are devastating to cardiac and thoracic surgery. We have outlined in this comment letter our concerns and suggestions to prevent harm to surgical practices and patient access to cardiac and thoracic surgery.

STS urges CMS to avoid these unintended negative impacts to Medicare patients and instead work with the national medical specialty societies and providers to find solutions that bring the most benefit to patients.

View full comment at: https://www.regulations.gov/contentStreamer?documentId=CMS-2020-0088-12857&attachmentNumber=1&contentType=pdf

Sincerely,

Joseph A. Dearani, MD

President

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Footnotes:

1/ https://www.cancer.org/cancer/lung-cancer/about/key-statistics.html

2/ https://www.cancer.org/cancer/lung-cancer/about/key-statistics.html

3/ https://www.cdc.gov/heartdisease/facts.htm#:~:text=Heart%20disease%20is%20the%20leading,1%20in%20every%204%20deaths

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0088-1604

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