American Medical Association
January 22, 2001
Raymond D. Bahr, MD
President
The Society of Chest Pain Centers and Providers
St. Agnes HealthCare
900 Caton Avenue
Baltimore, MD 21229
Dear Dr. Bahr:
Thank you for your letter expressing concern about the Health Care Financing Administration's policy on payment for Observation Services and seeking American Medical Association support for observation services.
As you may be aware the American Medical Association House of Delegates at its December 2000 Interim Meeting heard discussion on Resolution 823 ? Establishing a Medicare Ambulatory Payment Classification (APC) for Hospital Observation Status. Res. 823 was ultimately referred to the AMA Board of Trustees for decision. The Reference Committee considering the resolution heard testimony that was unclear on HCFA payment policy on the bundling of observation status and the resulting necessity for a specific APC on observation status and thus the resolution was referred to the Board.
The AMA has twice previously commented to HCFA on the value of observation codes - once in response to the FY2001 Fee Schedule final rule and later in response to the proposed rule on APC. In that letter we stated the following:
"Observation Care"
We do not agree with HCFA's decision to not separately pay for observation care, and urge HCFA to reconsider.
Many hospitals' emergency departments have obseevation units, including chest pain centers, for patients that need to be observed. Many patients that come to the emergency department, especially heart attack victims, cannot be accurately diagnosed. Withaut separate payment for services provided in an observation unit, physicians will be forced to choose between sending patients home prematurely, at significant risk, or unnecessarily admitting patients who simply need to be observed, at significant additional cost to the Medicare program.
January 9, 2001
Raymond D. Bahr, M.D., F.A.C.C.
President, The Society of Pain Centers & Providers
12139 Mt. Albert Road
Ellicott City, MD 21042
Dear Dr. Bahr:
Thank you for writing me about chest pain centers and observation services in emergency departments. As you pointed out in your letter, the ACC has been actively involved in developing guidelines on this issue. The College agrees that Medicare's new hospital outpatient prospective payment system presents a roadblock to the appropriate provision of observation care. That is why the ACC has been working closely with your organization (The Society of Chest Pain Centers and Providers - SCPCP) and others to modify Medicare payment policy.
It is encouraging that HCFA staff have committed (as much as they legally can) to revising their policy and providing separate reimbursement for observation care. ACC staff has been publicizing this development to press contacts with the AMA's American Medical News, Modem Healthcare, and many others. The College has publicized this development via its web page, Advocacy Weekly and in Cardiology.
We look forward to continuing to work with SCPCP and others to facility ensure that observation care can be delivered whenever and wherever it is medically indicated.
Sincerely,
George A. Beller, M.D., F.A.C.C.
President
cc: John W. Schaeffer, M.D., F.A.C.C. ? Chair ACC's Economics of Health Care Delivery Committee
Raymond D. Bahr, M.D.
January 22, 2001
Page 2
HCFA's blanket decision establishes policy that will have a substantial adverse impact on access to and quality of care. Alternatively, HCFA could establish a much more reasonable policy that allows payment for observation services under circumstances that will minimize or eliminate HCFA's concerns about potential abuses resulting from payment for these services.
I appreciate that you forwarded me the letter to you from Thomas Gustafson of HCFA. I believe that the Board now has sufficient material to consider as it finalizes its position on establishing an APC for observation services.
Thank you again for bringing your concerns to my attention.
Sincerely,
Randolph D, Smoak, Jr., M.D
