Oncology & Hematology Coding Alert

2011 Fee Schedule:

Will CMS Slash 2011 Conversion Factor by Over 30 Percent Versus Current Rates?

Oncology RVUs should stay close to 2010 levels.

Another season of nail-biting is under way, waiting to find out whether your Medicare payments will be slashed.

As most practices know, last June Congress voted not only to stave off a 21 percent cut to your Medicare pay, but also to increase your revenue by 2.2 percent. However, that vote only kept the cuts at bay through November 30. Effective December 1, your Medicare pay was set to drop by over 23 percent, unless Congress intervened to reverse the cuts.

As of publication time, the Senate and House had passed, and the President had signed into law, a measure to delay Medicare's 23 percent cut to the fee schedule conversion factor due to take effect Dec. 1. The delay pushes the possible cut to 2011 for payments with dates of service after Dec. 31, 2010. There are rumblings that another one-year patch to keep rates up is under consideration by Congress.

Some newly-elected Senators and House members will be in place in 2011, and it's unclear whether the current Congress will make changes affecting 2011 pay before January, or whether they'll leave the issues for the new Congress to handle, says Michael A. Ferragamo, MD, FACS, clinical assistant professor at the State University of New York at Stony Brook.

If those fixes don't pass, here's what's in store: "The calendar year 2011 Physician fee schedule conversion factor is $25.5217," notes the 2011 Medicare Physician Fee Schedule Final Rule (with comment period), printed in the Federal Register published on Nov. 29. This amounts to a dismal 30 percent cut compared to the current rate of $36.8729.

All of this leaves Part B practices in the dark about the future of payments yet again. "While Congress has provided temporary relief from these reductions every year since 2003, a long-term solution is critical," the Fee Schedule notes. "We are committed to permanently reforming the Medicare payment formula."

Get a Quick Oncology RVU Overview

According to the fee schedule, table 101, hematology/oncology should see a 0 percent change in allowed charges while radiation oncology can expect a one percent decrease. (Note that this does not take conversion factor changes into account.) This small change is partially due to the Medicare Economic Index, which rebased practice expense and malpractice relative value units (RVUs).

But be sure to check the numbers for the codes you report most often. Table 102 indicates you could see a 26 percent decrease for 77427 (Radiation treatment management, 5 treatments). This change is in part due to physician work RVUs dropping from their 2010 level of 3.7. The AMA RUC (Specialty Society Relative Value Update Committee) recommended 3.35 work RVUs, but CMS disagreed and decided on 2.92.

Resource: You can search the Federal Register here: www.gpoaccess.gov/fr/.

"The rule is written under current law, which means that it takes into account the schedule of negative updates to the SGR," said CMS's Amy Bassano during a Nov. 16 CMS Open Door Forum. "If the law were to change, we would put out revised files and rates to reflect any changes in the law," she noted.