April 25, 2014:
Osteopathic physicians are affected by a recent decision to make publicly available Medicare physician payment data. The AOA has prepared the following primer to provide details on the data release, limitations on the data, AOA's efforts to oppose this release, and how to correct your demographic data and protect yourself.
CMS Physician Payment Data Released
The data set of payment information for Medicare Part B services provided by more than 880,000 health care professionals in 2012 is now publicly available through the Centers for Medicare and Medicaid Services (CMS). The data, released April 9, show payment and submitted charges or bills for those services and procedures by the physician. The Physician and Other Supplier Public Use File (PUF) contains the following data on individual practitioners:
Name, Credentials, Gender, Complete Address;
Information from the National Plan & Provider Enumeration System (NPPES);
Information on utilization, payment (allowed amount and Medicare payment), submitted charges organized by National Provider Identifier (NPI), HCPCS code, and place of service;
Individual charges and payments for specific services;
Total numbers of beneficiaries, services, charges and Medicare payments; and
Standard deviations of Medicare allowed amounts, charged amounts, and Medicare payment amounts. The standard deviation indicates the variation from the average amounts.
In addition to downloading the full data set at the CMS website, physicians can search more directly by name and location.
CMS Admits Data Limitations
No attempts were made to modify the data. CMS notes that the dataset has limitations. For example:
The data may not be representative of a physician’s entire practice.
The information does not indicate the quality of care provided by the physician.
The volume of procedures performed by the physician may not be fully inclusive.
The data do not account for differences in the underlying severity of the patient’s disease.
The file does not include data for services performed on 10 or fewer Medicare beneficiaries.
Some physicians bill under their individual NPI and an organizational NPI. In those cases, a physician’s actual total cannot be determined because the individual’s portion cannot be identified when billed under the organization.
AOA's Opposition to Data Release
The AOA expressed strong concerns in a letter to CMS on Sept. 5, 2013, regarding the then-proposed release of physician data and urged CMS "to exercise caution when considering the release of individual level physician payment data." The AOA reiterated these concerns in an April 3, 2014 letter. The AOA will continue to advocate that public disclosure of data must be carefully implemented to include proper safeguards and context.
How to Correct Your Demographic Data & Protect Yourself
According to CMS, if a physician wants to correct demographic information about his/her NPI, they can do so through the agency’s website. Changes made to the NPPES demographic information will not be reflected in the CY2012 Physician and Other Supplier PUF as it represents the information available at the end of 2012. If you believe your NPI has been compromised or these claims do not reflect your true billing activity, please contact your Medicare Administrative Contractor (MAC).
All physicians should:
Make any corrections to their information in PECOS
Ensure their billing service is correctly entering their NPI
Verify their Medicare enrollment status
Look at their data – reporters, researchers, health plans, patients, competitors, and future employers are looking