The American Venous Forum is committed to promoting evidence-based best practices to ensure that patients have access to the highest quality care – especially the underserved.
We believe that vigorous advocacy in venous and lymphatic disease is critical to this commitment.
Update for “Stark Laws” or Anti-kickback Statute”
The threat of running afoul of the US Government’s “Stark Laws” or “Anti-kickback Statute” (AKS) has thrown many administrators or well-meaning providers into a cold sweat because of the potentially devastating penalties for violations of these sometimes arcane regulations. Not only are these regulations challenging to understand, they can conflict with each other. Change being the only constant, on December 2, 2020 the Department of Health and Human Services (HHS) Office of Inspector General published a new “FINAL Rule” regarding AKS and provider inducements, while CMS has clarified issues related to Self-referral. The attached document was prepared by the AMA in which the AVF now participates as a member of the surgical specialties section. The AMA actively lobbied for changes that would support our providers and patients. Several important changes were included in this Final Rule. This summary concisely explains a number of items which can directly impact the rules which govern the practice of medicine for many of our members. For instance:
- Is there a dollar amount below which physician remuneration is exempt from these regulations?
- Can I accept donations to provide cyber security technology and services from vendors, donors, patients?
- Can I supply transportation for patients to or from my office/hospital? How far and in what circumstances?
Click here to read the AMA summary. To learn even more you may read the entire entries in the Federal register by clicking the links below.
Enjoy this light reading. Perhaps considering sharing it with your attorney. There may well be opportunities.
Mark Iafrati MD
Chair, AVF Health Policy Committee
Proposed Response to the BCBS NC Coverage Policy
Dear AVF HPC members
I heard support from many of you regarding the proposed response to the BCBS NC coverage policy. Thanks for your quick reply as we were working under a deadline of today for submission. Click here to view the joint letter AVLS/SVS/AVF sent.
I am pleased that we continue to be able to provide constructive feedback to payors across the country with a unified expert opinion and that these efforts are starting to yield tangible benefits to our members and our patients.
I am looking forward to continuing a collaborative approach in 2021 as there remain plenty of challenges on the road ahead.
Updated LCDs from First Coast and Novitas
Dear AVF Members,
We are delighted to share with you updated LCDs for the Medicare Administrative Contractors (MACs) First Coast and Novitas. These LCDs which are scheduled to take effect on 12/27/20, are felt to be very reasonable and appropriate concerning the care of our patients with venous disease. Through the prolonged efforts of the AVF Health Policy Committee, in conjunction with the SVS and the AVLS Health Policy Committee, we have LCDs that finally are appropriate for patients, providers, and payers. In the future, hopefully these will either translate to a National Coverage Determination (NCD), or similar LCDs with the other MACs. Thanks to all the current and past members of the AVF HPC, and our friends at SVS and AVLS for this achievement.
Harold J. Welch, MD – President, AVF
Mark D. Iafrati, MD – Chair, AVF Health Policy Committee
Vein Ablation Policy Updates from Boston Scientific
Author Harold Welch, MD – AVF President
To AVF Members: Boston Scientific has been keeping a monthly update on health care payers’ policies towards endovenous ablation procedures. They have been forwarding their spreadsheet to us, and we wish to share it with you. It provides links to updated policies that may affect your patients. Please feel free to peruse it, and we will continue to provide updates as we receive them. We thank Boston Scientific for sharing this data with us.
AVF Advocacy in Action
The AVF Health Policy Committee, in collaboration with the SVS and AVLS have been busy advocating for our patients and our members. This week, we submitted comment letters to CMS (Centers for Medicare and Medicaid Services) to address several significant regulatory issues. The first addresses a long-standing non-coverage decision regarding catheter based mechanical embolectomy for Pulmonary Embolism. The second addresses a proposed severe further reduction in the reimbursement for radiofrequency ablations over the next two years, based on an erroneous assumption about the prices we pay for RFA catheters. By raising our collective voices on these important issues, we hope push our agenda of educating the regulators and ensuring access to these vital services for our Medicare and Medicaid patients. Please take a moment to review these letters and feel free to add your voice with direct communication to your legislators in support of these important issues.
Medicare Physician Payment Cuts – Urgent Call to Action
As you likely know, CMS has proposed a 7% cut in the Medicare payment rates scheduled to take effect January 1st, 2021. Multiple vascular societies are encouraging their members to contact their US Representative and US Senators to prevent these cuts, and the AVF is proud to be engaged in this effort. Please read the letter, and make your voice heard. Time is of the essence. Thank you.
Harold Welch, MD
CMS Preauthorizations for Vein Ablation Procedures in a Hospital Outpatient Setting
On July 1, 2020, CMS instituted a prior authorization requirement that was announced last year. Most vein procedures that are performed in a hospital outpatient setting will be affected by this change.
On May 28th, CMS had an Open Forum on their new program, and Dr. Mark Iafrati, Chair of the AVF Health Policy Committee participated. Dr. Iafrati has provided a summary of the Open Forum, as well as copies of the slides used. As mentioned, this program affects prior authorization for vein ablation procedures in a hospital outpatient setting only, at this time. Of course, the concern is that in the future, this will extend to all outpatient settings. The AVF Health Policy Committee, along with our sister societies, will be monitoring for future CMS decisions concerning vein ablation policies.
Can You Hear Me Now?
The AVF Seeks Its Voice in the AMA
How is your reimbursement for a given procedure determined by Medicare and insurers? Who makes up the billing codes for procedures? How are new technologies assigned codes?
The processes of revising reimbursements and coding occur through committees of the AMA House of Delegates, which make direct recommendations to Medicare, to which the insurers generally follow suit. They meet twice a year. There are national representatives from every specialty and field. The members of the American Venous Forum have not been represented in this forum – but we are working to change this.