• Email:
  • Password:
  • Remember Me
 
Print   Subscribe    Share
DPM,CWS,FCCWS
2012 Medicare Fee Schedule -- The New Reality

Last week, CMS released its final rule regarding the 2012 Medicare Physician Fee for Service schedule.  As we all know, effective January 1, 2012 there is a schedule physician fee service cut of 27.4%.  


What does this mean?  Well basically, we've been down this road before.  Each calendar year since 2008, Congress has chosen via legislation to avert and repeal the mandated SGR (Sustainable Growth Rate) cuts enacted in the 2003 Medicare Modernizaton Act.  As a result, because each previous cut needs to be recalculated into the SGR formula for the following year, we as physicians in the Medicare system are in line for a dramatic cut of 27.4%.  This is actually a decrease from the proposed 29.1% that the SGR was supposed to initiate on January 1.


Why did it drop from 29.1% to 27.4%?  In the recent health care legislation, there was language that a modest increase in primary care payments would not be affected, so the CBO and CMS agreed in part to increase the conversion factor 1.0018 to the 2012 level of $24.6712.  In 2011, the conversion factor is $33.9764.  In 2010, the second half of the year we enjoyed a conversion factor of $36.8729.  The reduction in the factor was also played in part by the third Five-Year review and the elimination of the work adjustment RVU.


So how does it affect podiatrists?


Here is a an Excel format showing the comparison from 2011 to 2012.  Now I am not trying to be an alarmist, but I know FOR A FACT, THAT THE APMA HAS NOT RELEASED THIS INFORMATION TO THE GENERAL PODIATRY MEMBERSHIP AND NOT A WORD IS OUT IN THE NEWS MEDIA.


http://presentelearning.com/upload/files/2012_PFS_Compare-2011.xls


Yes, my friends and colleagues, this is real.  Unless Congress acts (which we know will happen since its a major election year), these cuts will be in effect on January 1, 2012.  It is disturbing to review the numbers (I have included the new skin replacement codes with the 2012 reimbursements -- see my post on CPT Replacement Skin Subsitute Coding Changes) and that MANY podiatrists will probably be out of business by June 2012 if the cuts are not averted.


Get on the eAdvocacy website via APMA.  Call your local congressman's office.  Call your state senators.  Do what must be done.  There is no more time to sit on the sidelines, and hope that things fix themselves.  I know I can't survive on this fee schedule.  I hope this drums up enough replies that people see this for what it is.  Call your local news stations and see if they can report this story.  Just don't sit back and think this is going to be fixed by itself!


Eric J. Lullove, DPM


Excel table provided by AAWC Regulatory Committee



MEMBER COMMENTS
Re: 2012 Medicare Fee Schedule -- A Must Read Blog

I have a hard time believing that nobody has a single comment on this post.

 

I'm really surprised.  Open the Excel file and see for yourself.

 


Eric

Re: 2012 Medicare Fee Schedule -- The New Reality

You know what, Eric?  Over the past several years we've become numb to the issue and threats of payment cuts--1%, 2% 5.5% 10%, etc.   To look at the numbers is indeed nauseating because it all comes out of our profit margins, our overhead remains pretty much the same.

That being said, thanks to political pressure from many corners, each and every time these threatened cuts have never come to pass.  Its an annual rite of passage that sometimes is passed just before Christmas, sometimes not until January.  The outrage, which is completely justified, has wound up being much ado about nothing.  They've never fixed the formula, but have always passed temporary bills--which has resulted in teh escalation of the threatened cuts from one year to the next.  Of course, now it is too expensive for Congress to make the change.  It has become a bit like the liitle boy crying wolf.  Yes, I do fear the one day they won't pass something and we'll all be screwed royally.  But this time we're coming up on a presidential election year and politicians hate pissing off senior citizens and doctors both in an election year.

 

Again, I pray that this isn't the year that they fail to pass a bandaid measure and that they'll find a way to fix this mess once and for all--without being subject to a 30% pay cut.

Re: 2012 Medicare Fee Schedule -- The New Reality

sadly, I agree with Brandon.  I guess I'm just so numb to this now.  But then again, we're a country of the "2-minute Drill".  We love winning at the last second instead of a slow, steady game.  I think we'll see a flurry of responses and reactions near the end of the congressional season or at least at the beginning of 2012.  Medicare will withhold payments until congress passes some type of patch (again).  Repeat for N years.

Re: 2012 Medicare Fee Schedule -- The New Reality

Eric -it's interesting you bring this up, and it is good you are being proactive. My question is:
1) Why is not our leadership bringing it up? G-d Forbid this goes through, as Wenjay points out, offices will close.
2) Why must be deal with this every year? enough is enough fix the damn formula already.

To me, it reflects a lack of respect to the medical profession at large. The once revered doctor is no longer.

I don't know if this is true but I was reading online that congrespeople actually get a raise every year and have to vote to not take the raise....can someone confirm or correct this....?

What other professions are faced with the "threat" of a decrease in pay along the lines of 25%?
(Which is actually more that that as other insurances follow Medicare's lead).


It is good Wenjay and Brandon are "numb" and don;t let it bother them, unfortunately, I am with feeling with regards to this matter and bothered by it.

Re: Re: 2012 Medicare Fee Schedule -- The New Reality
Quote:

Eric -it's interesting you bring this up, and it is good you are being proactive. My question is:
1) Why is not our leadership bringing it up? G-d Forbid this goes through, as Wenjay points out, offices will close.
2) Why must be deal with this every year? enough is enough fix the damn formula already.

To me, it reflects a lack of respect to the medical profession at large. The once revered doctor is no longer.

I don't know if this is true but I was reading online that congrespeople actually get a raise every year and have to vote to not take the raise....can someone confirm or correct this....?

What other professions are faced with the "threat" of a decrease in pay along the lines of 25%?
(Which is actually more that that as other insurances follow Medicare's lead).


It is good Wenjay and Brandon are "numb" and don;t let it bother them, unfortunately, I am with feeling with regards to this matter and bothered by it.


I agree with the above comments --especially the idea that we have become numb to the threat that this legislation posses.  Since 2008, we have be threatened with the cut but it always has miraculously gone away at the 11th hour, and we have grown to expect a similar "fix" at the last minute.  We absolutely need to be fighting this, and I am surprised that the APMA has not made a bigger deal about this -legislative issues are their bailiwick.

I would definitely agree that there is loss of respect, overall, for the medical profession.  This is especially true following recent discussions of healthcare reform --discussions which have vilified physicians as only "in it for the money."  Remember the Obama flap saying how much a surgeon would make with an amputation...

Society is changing, and we must adapt as well.  I have patients who come in and are aggravated that they have to pay their insurance copays--they feel entitled to free care, and as such they perceive each of use as a conduit for that care, and nothing more.   Perhaps I'm feeling overly cynical this morning --i had a number o these instances last week--and it is my hope we will be able to work with legislators to establish a payment plan that is both cost effective as well as fair to healthcare providers.

Re: Re: Re: 2012 Medicare Fee Schedule -- The New Reality
Quote:

I agree with the above comments --especially the idea that we have become numb to the threat that this legislation posses.  Since 2008, we have be threatened with the cut but it always has miraculously gone away at the 11th hour, and we have grown to expect a similar "fix" at the last minute.  We absolutely need to be fighting this, and I am surprised that the APMA has not made a bigger deal about this -legislative issues are their bailiwick.

I would definitely agree that there is loss of respect, overall, for the medical profession.  This is especially true following recent discussions of healthcare reform --discussions which have vilified physicians as only "in it for the money."  Remember the Obama flap saying how much a surgeon would make with an amputation...

Society is changing, and we must adapt as well.  I have patients who come in and are aggravated that they have to pay their insurance copays--they feel entitled to free care, and as such they perceive each of use as a conduit for that care, and nothing more.   Perhaps I'm feeling overly cynical this morning --i had a number o these instances last week--and it is my hope we will be able to work with legislators to establish a payment plan that is both cost effective as well as fair to healthcare providers.

My prediction in this matter is that it is crunch time for the government to reduce spending.  In that sense, this is the first year in memory that the second most powerful lobby (It's Insurance/Pharmacy 1-2) the pharm industry has been slated for deep cuts in Medicare Part D and inaugurate their place on the downward spiraling tarmack.

 

Unlike Ryan, I cannot blame the APMA.  There is no way the APMA is going to have impact as an isolated entity.  I agree with them joining the other healthcare politicos (A.M.A., A.C.A) to form a cooperative attack as their best approach.  At least it builds a better coalition for us to live in. 

 

I see "The Reality"to be that this is the year for action (as in the Debt Ceiling and the Flight Navigators) and the 29% cut that has become the 27% cut will be reduced to 8-15% before january and we will be expected to work harder for less recompense and say "Thank You, I have a paycheck" like two of my five kids with college degrees that are working for $38 and $32,000 respectively.

 

For 40 years, I have areputation of living on the positive end of the cutting edge of our profession.  My first website in the 90's was www.dpmsurvival.com.  I coined the term "HMOitis" which has been used over and over.  My first company interprofessionally was "The OTC Connection" Mentoring DPM's Into In-Office Dispensing.  I was called "The Father of In-Office Dispensing" by Podiatry Management in 1996 and in those days, I was 100% In-plan.

 

I now have my mentoring basket filled with podiatry treatment services that expand core practices (not Income Streams like shoes, vitamins and creams which are adjacencies).  "New Income Streams Not Bound to Insurance".  My Podiatry Exclusive Orthotics, Lasers, Plant Based Injectables, Aesthetics, Toenail Reconstruction to name a few. 

 

I continue to ask my fellow DPM's to find out their "One Hour Turnkey" and drop out of any plans that are not profitable in order to free up time to visit and invest in New Income Streams on our own without me as their private path for acculturation.

 

I currently state that "It is our office policy that inferior treatment dictated by insurance companies isl not the only tretament offered by The Foot Typing Center @ LIfeStyle Podiatry (please adapt)" as a proactive statement to my patients as to who is to blame".

Commercial Disclaimer: I profit from the next statements as a Podentrepeneur only if my fellow DPM's profit as well:

My current interpersonal company is The FootHelpers Corp, where I vett New Income Stream Markets for Podiatry.  I then create a short list of candidates within each market.  Then I implement them in practice until I find the winner.  I develop experiential presentation and marketing programs that upgrade the goods and services I offer in practice.  Then and only then, I partner with those companies and become one of their consultants into podiatry (at their expense) and educate and assist my colleagues into implementing and maintaining these programs in practice without any added expense to them for my companies education, troubleshooting and care.

I am, on the cutting edge, the Father of "Concierge Vetting of New Income Streams" into Podiatry and the DPM's working with me are being micromanaged less, they are less "numb" and they have a sense that they have accomplished positive change Proavtively.

I am holding "Insurance Slave Freedom Workshops" around the country and by invitation to small groups of DPM's and I work globally by email, dropbox and internet to get those interested in working with me.  I accept visitors to my practice for "Mini-Fellowships" for 1-2-3 days to see these Income Streams working in real time.  I am having one of my best years in Podiatry in 2011, at 65!

I predict a culture where insurance bound income will continue to drop regardless of our input. 

However, I predict there is a bright future for Podiatrists willing to invest time, money and energy in acculturating.

 

Dennis

Re: Re: Re: 2012 Medicare Fee Schedule -- The New Reality
Quote: 

I agree with the above comments --especially the idea that we have become numb to the threat that this legislation posses.  Since 2008, we have be threatened with the cut but it always has miraculously gone away at the 11th hour, and we have grown to expect a similar "fix" at the last minute.  We absolutely need to be fighting this, and I am surprised that the APMA has not made a bigger deal about this -legislative issues are their bailiwick.

I would definitely agree that there is loss of respect, overall, for the medical profession.  This is especially true following recent discussions of healthcare reform --discussions which have vilified physicians as only "in it for the money."  Remember the Obama flap saying how much a surgeon would make with an amputation...

Society is changing, and we must adapt as well.  I have patients who come in and are aggravated that they have to pay their insurance copays--they feel entitled to free care, and as such they perceive each of use as a conduit for that care, and nothing more.   Perhaps I'm feeling overly cynical this morning --i had a number o these instances last week--and it is my hope we will be able to work with legislators to establish a payment plan that is both cost effective as well as fair to healthcare providers.


Ryan,


You have to remember, that this is a 26.4% decrease in the CONVERSION FACTOR -- not the MFFS schedule...If you look at the Excel spreadsheet, it reflects an overall 55-60% decrease in all Medicare Part B Physician Fee Reimbursements.

 

This is problematic that this is in my opinion, what the APMA, AMA, AOA have not been very proactive in telling their memberships, as to not provide the "fear" factor, but an effort to hide the real truth from their own failures at not working with Congress to fix the problems.  We all agree (most of us) that 9% approval ratings for Congress is unacceptable.  I don't want to get political, but we cannot survive, no matter what.



I will agree with Dennis, that we are probably looking at a 5% Conversion factor fee reduction, which will be around a 10-15% reimbursement reduction for 2012.  

 


But yes, its time that we stop thinking that "Congress will fix this" mentality and really start getting proactive....or we need to find other avenues of employment. 

 


You know, Lowe's or Home Depot looks good now....stable benefits, salary...etc....maybe open a custom wood shop orthotic lab in the home decor isle?



Re: 2012 Medicare Fee Schedule -- The New Reality

Brandon:

i agree that it is unlikely that a single cut in reimbursements of such a magnitude will go though in an election year.  Many MDs would drop out of Medicare under such circumstances.  Podiatrists? I don't want to go negative on our profession but it is very tough to get unified action on financial issues.  After all, is not the main thrust of APMA action now to make sure that we don't get removed from Medicaid?  Perhaps that is correct in principle but I really don't want to fight to be a Medicaid provider.  When do we take a step back, look at our self worth and the value of our services and be willing to draw a line in the sand?

Ed

Re: 2012 Medicare Fee Schedule -- The New Reality

Ed -

It amazes me the line wasn't drawn long ago, you make an excellent point.  Barry Block, DPM JD iin the latest hard copy of "Podiatry management" writes much of what you just said. Millions of dollars wasted on this Title 19 - Medicaid, his column was titled something like we are our own worst enemy.

Re: 2012 Medicare Fee Schedule -- The New Reality

Less than 30 days away - you guys still think no cuts will be made? The current state of the economy stinks. I don't see how we will potentially avoid a hit. I hope I am wrong.
I don't see where the hail mary saving pass is coming from.

Incidentally, does anyone hear from the APMA on an action plan? Or are we supposed to first wait get cut then try and act? What ever happened to being proactive? Shouldn't we of been making a "big stink" about this to prevent impending cuts?

Re: Re: 2012 Medicare Fee Schedule -- The New Reality
Quote:

Less than 30 days away - you guys still think no cuts will be made? The current state of the economy stinks. I don't see how we will potentially avoid a hit. I hope I am wrong.
I don't see where the hail mary saving pass is coming from.

Incidentally, does anyone hear from the APMA on an action plan? Or are we supposed to first wait get cut then try and act? What ever happened to being proactive? Shouldn't we of been making a "big stink" about this to prevent impending cuts?

As I have predicted, the consensus on this thread regarding a cut is that one is going to happen and that we should not crisis react but plan an agenda for the future.

 

It seems to also reflect as Dr's Kass and Block so accurately stated that we must do this on our own as our families needs are not in sync with the political needs of those who represent us (sound familiar in the big picture).

But Jeff, realistically are we capable of preventing impending (and inevitable additional) cuts?

 


I remain ahead of those  working with my podiatrists as The FootHelpers Corp which offers:

Insurance Slave Freedom via Income Streams Adjacent to Insurance Bound Practice that You Can Control.

As I have focused successfully on feeding my family, I can mentor you into feeding yours.

Dennis

Re: 2012 Medicare Fee Schedule -- The New Reality

"Are we really capable of preventing proposed cute?"Certainly not, if we don;t proactively voice our opinion as a united profession!


I don't mean to imply just Podiatry here, as ultimately we are small potatoes, however, I imply, the medical community at large.

Why hasn't leadership called for a "million doctor march" down on Washington?
Why have doctor (of all kinds) not been on television being interviewed explaining to the public the ill effects of proposed cuts on their care. [or is explaining why flip flops are bad for you really more important?]

If you were a politician being faced with having to make budget cuts and do not hear opposition form those you need to cut  - why wouldn't you cut them?

The fact we are in this position year after year - is an absolute outrage, and is a poor reflection on the medical communities leadership.

(as I mentioned in the blog "pedicure infection - refund? - this demonstrates a total lack of respect to the medical profession, we are no longer valued.)

Doctors need to take a stand! The joke is we are not even asking for a raise - which is what most professional athletes strikes are about - like the current NBA lockout that just ended. We, in turn, are simply asking for the status quo to remain in effect, so that we may keep up with rising costs and inflation.


[Status quo is actually a pay cut when you factor in all these costs.]

Has anyone looked at the price of ethyl chloride spray lately? when I started in practice about 16 years ago, I could swear the stuff was about 8.50 a bottle. It now costs between 35-40 dollars a bottle plus , now you have to pay a biohazard material charge for it.

i wish we were more proactive and less passive in our approach with regards to this issue.

Less than 30 days away....APMA  - what exactly is our plan? Do we have one? Do we need to worry or do you have this all wrapped up and this is why we haven't heard from you? Please inform.

Re: 2012 Medicare Fee Schedule -- The New Reality

Jeff:

I think that the leadership of the associations such as AMA, APMA etc. take action in a manner so as to not "rock the boat" as much as possible.  AMA endorsed Obamacare and APMA stood neutral. The organizations attempt to be "mainstream" and go with the flow in Washington, DC.  It is the specialty organizations that really take on a stronger activist role.  For example, the ENT specialty organization was very effective at obtaining increased reimbursements for office based balloon sinuplasties for 2010.

I have been a member of the AAPS (American Association for Physicians and Surgeons) since the early 1990s which is targeted at supporting the private practitioner.  We really need an ad hoc organization separate from APMA that can assume the activist role.

Re: 2012 Medicare Fee Schedule -- The New Reality

Eddie - so tell me where is "going with the flow" going to land us as of Jan 1st? Let's all place our bets now. We will then be back in less than 30 days and will know who the "podiatric prophets" are.....I say going with the flow is the wrong move.

Re: 2012 Medicare Fee Schedule -- The New Reality

Jeff:

I would encourage all to take a look at the AAPS:  http://www.aapsonline.org/
Podiatrists are currently in the "associate" member category but that could change if there was sufficient interest.  If you look at the philosophy of AAPS it will be obvious that I do not approve of a number of  actions of the APMA.  AAPS encourages physicians to leave Medicare and the third party payment system as much as possible.  Yes, I am still a Medicare provider but am weighing all options.  There need be a "critical mass" of non-third party participants that effectively network before we will see real change.

We do need a specific organization that represents our interests to payors and government.  Reimbursements are being reduced via a number of mechanisms: 1) replacing CPT codes with lessor paying codes, 2) not allowing providers to use certain codes, 3) RBRVS devaluations and the like. 

Some examples:   1) The code for diagnostic ultrasound exam 76880, was replaced with 76882 and 76881.  It is suggested that podiatrists should use primarily the absurdly low valued 76882.  This change was made with APMA in attendance.  I had made numerous appeals to APMA on this issue with no response.  2) We have "directives" from our Medicare rep in Texas that podiatrists should not bill code 11755 and almost never, the higher level codes such as 99214.

Re: 2012 Medicare Fee Schedule -- The New Reality

Eddie - All the points you make in this post are taken to heart by me. I would encourage you to make these issues more public. What makes these public forums such as here and PM NEWS great is that they afford us as a profession a way of communicating with and to each other.
The same way I am asking what is the APMA doing with regards to MEDICARE fee schedule.
Our voices need to be heard.

To participate or not to participate that is the question - this is a story for another day.

Re: 2012 Medicare Fee Schedule -- The New Reality

I was actually starting to get a bit worried this time because there hasn't yet been the typical information that has come out by now regarding pending action in Congress to deal with the doc-fix and pending payment cuts.  So this morning, I ran across the following, copied from PM News:

 

-----------------

A last-minute plan is shaping up in Congress to postpone a massive reduction in Medicare reimbursement to physicians for 2 years, and freeze rates in the meantime. The political will to avoid a 27.4% pay cut scheduled for January 1 seems to be there on both sides of the aisle. Last week, House Majority Leader Eric Cantor (R-VA) said that Congress would pass legislation by December 16 to avert what physicians consider a catastrophic blow to their practice finances and seniors' access to care.

The question is how Republicans and Democrats will strike an agreement while they are fighting tooth and nail over other end-of-year matters, such as extending a payroll tax cut for workers, and unemployment benefits for the jobless.

Source: Robert Lowes, Medscape News [12/6/11]

 


------------------

 

Fact is that this is a budget--political issue.  I would imagine the politicians are more afraid of the grief they'd hear from the senior citizen organizations such as AARP and the senior vote itself than they are of the lobbying efforts from APMA and AMA combined.


Stay tuned for more details as they arise.

 


Brandon Macy

Re: 2012 Medicare Fee Schedule -- The New Reality

Brandon - What happened to the "nerves of steel"? Weren't you one of the those who assumed a "bail out" would come?
I read the same blog this morning and for the first time in 2011 actually breathed a sigh of relief.

I agree with you that the fallout from such a cut could potentially be disasterous for our politicians. Could you imagine first a "tech bubble" then a "bank bailout", then a "mortgage crisis" to be topped off with a "Medicare crisis" - I don't think Congress wants to add another something to their "to do list". 
And by them "freezing the wages" for two years, in a way it's a win for them as inflation is not factored in. 

 

Re: 2012 Medicare Fee Schedule -- The New Reality

Well, Jeff--I hadn't yet gotten to the point of losing sleep over it, but I was going to a one day seminar with information reagrding Medicare's plans for 2012.  There were plenty of people there who would be in the know, so I asked around.  One person had heard "something", then this little article turned up.  I did receive information that APMA folks are always up "on the hill" in Washington and have been putting in their two cents' worth--and being heard.   To me, APMA can't get things like this done by themselves but are doing what they can.  Major political endeavors like this take a lot of sustained pressure from a variety of interested parties.

 

Interestingly enough, I heard a story that back in the 1960s, podiatrists weren't going to be included in Medicare, but Lady Bird Johnson's podiatrist put in the word to her, she lobbied LBJ, and the rest is history.

Re: 2012 Medicare Fee Schedule -- The New Reality
Any chance Michelle has painful bunions?
Re: Re: 2012 Medicare Fee Schedule -- The New Reality
Quote:

A last-minute plan is shaping up in Congress to postpone a massive reduction in Medicare reimbursement to physicians for 2 years, and freeze rates in the meantime. The political will to avoid a 27.4% pay cut scheduled for January 1 seems to be there on both sides of the aisle. Last week, House Majority Leader Eric Cantor (R-VA) said that Congress would pass legislation by December 16 to avert what physicians consider a catastrophic blow to their practice finances and seniors' access to care.

The question is how Republicans and Democrats will strike an agreement while they are fighting tooth and nail over other end-of-year matters, such as extending a payroll tax cut for workers, and unemployment benefits for the jobless.

Source: Robert Lowes, Medscape News [12/6/11]

  


Brandon,

Thanks for putting this post up.  However, I will answer your last question with another one....

 

Why do you think Congress will act by December 16?  Is it even possible?  The one thing I have learned about Congresspeople -- when the Camera is ON, they say anything to win votes....its what said behind closed doors and the camera isn't on that the American People need to hear.


This is crap.  I really am worried this time.  As a solo practitioner in a HEAVY medicare-based state (Florida), I can only imagine what the commercial payers are frothing at the mouth to pay me at 80% of Medicare rates for office visits....should be nice to see a BCBS patient for an office visit, get paid around $21.00 (83% of MFFS for 2012) and have to refund $9.00 to the patient out of their $30.00 copay...this should be fun.


Oh and lest I forget, BCBS will still collect premiums and never have to write a check or send me an EFT for services....



Re: 2012 Medicare Fee Schedule -- The New Reality

Any references to dates and deadlines has to do with currently planned recess/adjournment dates for the holidays.  You don't think they want to stay in session for a minute longer than necessary, do you?  It has been enough of a don-nothign Congress as it is.  In the end, they won't cut fees by 27% any more than they'll cut Social Security benefits--they're going to risk pissing off the senior vote in an election year?  It would be political suicide.


Unpopular legislation gets passed early a term, counting on the electorate to forget by the time reelection is in the works.  I admit to being a bit cynical, but in this case I believe it to be a political reality.  It is partof why I believe ther should be term limits on Congressmen and Senators.

Re: 2012 Medicare Fee Schedule -- The New Reality
Ok everyone, President Obama will have signed the 60-day extension for the Medicare "doc fix" before he leaves for Hawaii. Basically, and most likely, the offset of the 26.4% Medicare fee cut will most likely come from the hospital outpatient reimbursement schedule. As I previously posted, HOPD visits will be cut roughly 70-80% and this will most likely affect physicians who practice in hospital-owned medical clinics, wound centers and private offices owned by hospitals. Basically, any POS of "22 -- outpatient hospital" will be cut as above unless Congress figures out a different way to pay for the SGR reversal and payroll tax reduction. Have a Happy Holiday Season, Eric