The Centers for Medicare and Medicaid Services (CMS) on July 1 published a proposed rule that—if it takes effect—would eliminate payments for the outpatient and inpatient consultation codes used by many ID physicians, starting in 2010. Under the CMS proposal, physicians would instead use the “new office patient” and “initial hospital visit” codes; a new modifier would be established and used by the admitting physician to distinguish her or him from physicians who provide specialty care. The money previously allocated to consultation codes would be shifted to other evaluation & management (E&M) services, particularly in the outpatient setting.

In theory, private insurers could still allow use of the consultation codes, but in practice, many insurers follow CMS’ lead.

The proposal appears designed to provide incentives for primary care—an important priority for health care reformers. However, IDSA and other specialty societies argue that it would do so at the expense of ID and other purely cognitive specialties, and may not be cost-effective in the long run.

“The proposal fails to acknowledge the unique nature of ID consultations, which require not only time to complete an exhaustive clinical evaluation and to review medical history, but also the expertise to analyze and synthesize the medical data into meaningful recommendations that are individualized to patients’ needs,” said Larry Martinelli, MD, FIDSA, past chair of IDSA’s Clinical Affairs Committee. “Nor does the proposal account for the work ID physicians do when first evaluating critically ill hospitalized patients who are often immune-compromised, suffer from multiple organ system dysfunctions and co-morbidities, and have endured prolonged inpatient stays.”

The final rule is due out in November. In the meantime, IDSA continues to urge CMS and members of Congress not to make this change, which would perpetuate and worsen an already inequitable payment system. See IDSA’s website for information on how you can help make the case.

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