Endocrine Insider
August 19, 2009

(See full issue)

As recently reported in Endocrine Insider, the Centers for Medicare and Medicaid Services (CMS) has proposed, through the 2010 Medicare Fee Schedule Proposed Rule, to eliminate all inpatient and office/outpatient consultation codes. In place of the consultation codes, physicians will be required to submit claims for new or established office visits or initial hospital stays. CMS is increasing payment for office visits by approximately six percent and for initial hospital stays by approximately two percent to offset the loss of income expected through the elimination of the consultation codes. CMS predicts that endocrinologists will still come out ahead, with a net increase in reimbursement of approximately three percent in 2010.

The Endocrine Society understands that this change will result in a loss of income for many of its members; some estimate that loss to be in the 15 to 20 percent range if the proposed elimination of consultation codes is included in the final rule.

The Endocrine Society will be submitting comments to CMS voicing its concern with the elimination of these codes and the negative effect it will have on Society members. We encourage all physician members to submit their own comments to CMS, expressing how their practice and reimbursement may be affected. Comments can be mailed electronically to CMS by going to www.regulations.gov and entering the docket number CMS-2009-0058-0608.1 in the keyword search (document is titled Medicare Program: Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B CY 2010). Remarks can be submitted after the document is retrieved.  If preferred, comments can be sent through the U.S Postal Service to:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1413–P
P.O. Box 8013
Baltimore, MD 21244–8013.

Members may use the sample letter below, or may choose to provide their own comments. All comments must be received by CMS no later than 5 pm, Monday August 31, 2009.

Sample Letter to CMS:

As a practicing endocrinologist, I am extremely concerned to learn about CMS’ proposal to eliminate the use of consultation codes for both inpatient and outpatient services. While CMS contends that no major difference exists between office visits and consultations, the fact remains that physicians wishing to provide quality care to their patients with complex problems still need to take a detailed medical history and examination, review the entire medical record, and review any imaging studies or laboratory tests that have been performed prior to making a diagnosis. They then must send the results of their examination back to the referring physician. I believe this work is different from that of a new or established office visit, and does account for the modest increase in reimbursement provided by consultation codes.

A second area of concern related to the elimination of consultation codes is that the purpose behind such a proposal is to provide greater compensation to primary care physicians at the detriment of subspecialists. While I support the work and vital importance of primary care medicine, taking reimbursement funds away from subspecialists like endocrinologists, who are also facing serious workforce shortages, will only create additional hurdles for patients trying to access important medical care. Little benefit is derived from this reallocation of funds if patients have a primary care physician but cannot see a subspecialist in a timely manner for a complex medical condition. I request that CMS reconsider this flawed proposal.