AAN Members: Take Action in Response to the Medicare Cuts for Nerve Conduction and EMG Studies

November 27, 2012

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AAN members are encouraged to contact the Centers for Medicare & Medicaid Services (CMS) to oppose the cuts to nerve conduction studies (NCS) and electromyography (EMG) codes that were announced in the 2013 Medicare Physician Fee Schedule (starting on page 69066). CMS will severely reduce payment for EMG and nerve conduction tests beginning on January 1, 2013. Because of the circumstances that accompany the rulemaking process for new codes such as these, there was no warning that cuts of this size were coming. This left everyone affected with only 60 days to prepare.

What is the AAN doing?

We know our members cannot absorb these cuts during what is already a challenging time. The AAN is working on every angle to mitigate this unprecedented action by CMS. First, we are closely coordinating our efforts with our partners at the American Association of Electrodiagnostic and Neuromuscular Medicine and the American Academy of Physical Medicine and Rehabilitation. We are actively meeting with key members of Congress and we have a call scheduled with decision–making officials at CMS this week. A free webinar is scheduled on December 4 for all interested AAN members.

How can you help?

If the proposed cuts to NCS and EMG will affect your practice, please follow the steps below to submit official comments to CMS. Public comments are due December 31 by 5:00 p.m. ET. Note that submissions will be posted publicly.

To share your comments with CMS:

  1. Enter your contact information and paste (or upload) your comments at: http://www.regulations.gov/#!submitComment;D=CMS_FRDOC_0001–1076
  2. Refer to file code CMS–1590–FC in your comments
  3. Include specific examples of actions (e.g., layoffs, cutbacks, patient selection) you/your practice are making or plan to make when these cuts take effect
  4. Discuss how these changes will affect patient care
  5. Ask CMS to work with the AAN and other stakeholders to work together to find a solution to this drastic action
  6. Hit “submit” at the bottom right–hand corner of the page
  7. Send a copy of your comments to advocacy@aan.com
  8. Encourage your colleagues to do the same!

Sample Comments

Ms. Marilyn B. Tavenner
Principal Deputy Administrator, Centers for Medicare & Medicaid Services
Department of Health and Human Services
RE: CMS–1590–FC [2013 Medicare Physician Fee Schedule Final Rule; Nerve Conduction Studies/EMG Values]

Dear Ms. Tavenner,

As a neurologist who routinely uses nerve conduction studies and EMG to diagnose patients with neurologic illnesses such as carpal tunnel, ALS, muscular dystrophy, and neuropathies, I am concerned that the values for these tests set by the 2013 Medicare Physician Fee Schedule Final Rule will not only severely restrict patient access, but will delay timely diagnosis and appropriate treatment of these debilitating conditions.

The announcement of these cuts on November 1 leaves physicians and practices only 60 days to prepare for extraordinarily large cuts. Under common diagnostic scenarios, the cumulative reduction for new code bundles could reach more than 50 percent. In my practice, cuts of this size will lead to _________________ (add specific details about the impact and actions you will take as a result).

I strongly urge that you reconsider the scale of these reductions to ensure that Medicare beneficiary access to high quality care is not adversely impacted. I ask that you work with the American Academy of Neurology and other key stakeholders to find a solution to significantly mitigate these cuts to allow more time to adapt to any payment adjustments for nerve conduction studies and EMG tests.

Sincerely,

__________
(add your name)