October 7, 2020
American Venous Forum Petitions CMS on Proposed 2021 Reimbursement Changes
October 7, 2020—The American Venous Forum (AVF) announced that the AVF Health Policy Committee has submitted comment letters to the United States Centers for Medicare and Medicaid Services (CMS) to address several significant regulatory issues.
The first letter was drafted in response to the request for comments on the CMS Proposed CY2021 Physician Fee Schedule Rule. In the letter, AVF addressed a long-standing noncoverage decision regarding catheter-based mechanical embolectomy for pulmonary embolism (PE). AVF requested that national coverage determination (NCD) 240.6 Transvenous (catheter) pulmonary embolectomy, be added to the list of outdated/obsolete NCDs that are being considered for removal in Section J pages 523-533 of the Proposed Rule.
The AVF noted in the letter that withdrawal of this NCD should be prioritized because of the COVID-19 pandemic. It stated that there is rapidly mounting evidence in the peer-reviewed clinical literature about the link between COVID-19 and thrombotic complications, including a high incidence of acute PE and venous thromboembolism.
In an October 5 letter to CMS Administrator Seema Verma, AVF along with the American Vein & Lymphatic Society (AVLS) addressed a proposed “severe” further reduction in the reimbursement for radiofrequency ablation (RFA) over the next 2 years, based on an erroneous assumption about the prices that providers pay for RFA catheters.
According to AVF and AVLS, a proposed Conversion Factor of $32.26 implemented in 2021 would push many office-based practices to the edge of insolvency or motivate office-based doctors to close their offices and join hospital groups, which reduces access to care and increases costs to Medicare. The two societies stated that they support the new codes for evaluation and management services and foresee their usefulness in care scenarios encountered in usual patient care.