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History

COCA was formed on January 13, 2006 when forty-five cardiologists, administrators, and cardiac cath lab operators attended the inaugural meeting in Nashville, TN.  The primary impetus for this meeting was a Proposed Decision Memo issued by the Centers for Medicare and Medicaid Management  (CMS) in October 2005 to repeal the National Coverage Determination (NCD) for cardiac catheterization performed in other than a hospital setting, citing insufficient evidence to determine if net health outcomes of cardiac catheterizations performed in non-hospital outpatient cath labs (OPCLs) are comparable to cardiac catheterizations performed in the outpatient hospital setting.    CMS recommended that cardiac catheterization in a OPCLs be covered at the discretion of local Medicare carriers. 

As a result of this meeting, the attendees agreed to establish a national organization to represent OPCLs on a wide range of issues to CMS and other entities.  Since the CMS justification for the repeal of the NCD was largely based on quality issues, the members decided that one of the primary purposes of COCA would be to demonstrate the quality of their facilities by requiring that each member facility be accredited by either The Joint Commission or AAAHC and agree to participate in the collection and reporting of clinical data for maintaining and improving quality of care. 

As the meeting concluded, the membership elected a Board of Directors, who in turn elected officers and established committees to work on quality initiatives and the reinstatement of an outpatient cath lab NCD.  Work began on these critical issues when a new issue arose in February 2006 of such significance that COCA was forced to redirect all of its focus until the present. 

At a Town Hall meeting on February 15, 2006 CMS proposed revisions to the practice expense (PE) component of RVUs that would significantly reduce reimbursement for technology-based outpatient procedures in 2007 and beyond.  However, the proposed impact on reimbursement cardiac cath procedures was so severe that if implemented, the reimbursement would fall significantly below the cost of performing the procedures and  most OPCLs would be driven out of business. 

COCA led the way in alerting the cardiology community about the planned changes.  Our analysis of the proposed PE RVU changes indicated that they would result in draconian reductions in reimbursement for services performed in OPCLs.  In addition to various errors and omissions in the data used for cardiac cath codes (such as missing data for the patient post-procedure recovery time phase), the model did not accurately reflect either the direct or indirect costs associated with current cardiology office practice expenses.

After submitting comments to CMS concerning the proposed PE RVU changes, COCA worked to galvanize the cardiology community over the issue and build a consortium of advocacy groups such as the Cardiology Advocacy Alliance, Cardiology Leadership Alliance, and others.  COCA has also worked with the ACC and SCAI to make them aware of the impact on our members and keep them informed of our activity. 

COCA extended its efforts by hiring Marshall Brachman, a seasoned Capital Hill lobbyist, to represent its interests with members of Congress and their staff.  COCA members regularly contact their individual state Congressional delegations to educate them on the PE RVU issue and asking their help by contacting CMS to request them to develop an equitable reimbursement solution. 

COCA will continue to focus on the issues brought on by the CMS PE RVU changes until a fair resolution is reached. COCA will also proactively focus on other regulatory issues affecting its members in the future. In addition, COCA plans to reengage its initial goals of demonstrating its members' clinical quality outcomes by developing an effective reporting mechanism and helping them achieve 100% accreditation compliance.