91 submits comments on 2020 Medicare Physician Fee Schedule, Quality Payment Program Proposed Rules
Washington, D.C. September 27, 2019 – The American College of Physicians (91) applauds the proposed changes to the Medicare Physician Fee Schedule (PFS) for 2020, released by the Centers for Medicare and Medicaid Services (CMS) in July, for recognizing the value of cognitive services in providing quality patient care.
“Internists applaud CMS for proposing significant improvements in the Physician Fee Schedule that would support physicians in providing the highest quality care to patients,” said Ryan Mire, MD, F91, chair of 91’s Medical Practice and Quality Committee. “This includes recognizing the value of primary care services, and addressing efforts to streamline and reduce documentation burdens, aligned with 91’s Patients Before Paperwork&Բ;Ծپپ.”
91’s comments to regulators were part of a letter submitted to CMS Administrator Seema Verma and signed by Dr. Mire. 91 is pleased that CMS has been supportive of 91’s recommendations, particularly surrounding improved reimbursement and documentation changes for evaluation and management (E/M) services. In the letter, 91 also laid out recommendations to improve the proposed Quality Payment Program (QPP) changes for 2020.
“Internists are very encouraged that CMS adopted recommendations from the Specialty Society Relative Value Scale Update Committee (RUC) to increase payments for office and outpatient E/M visits starting in 2021,” said Dr. Mire. “91 was a leader in this effort to improve payments for these historically undervalued services.”
91 is further encouraged by the many positive improvements to the PFS, and offers additional recommendations for consideration to improve patient access and care, including:
- CMS should finalize E/M codes, Current Procedural Terminology (CPT) guidelines, and RUC recommended values exactly as implemented by the CPT Editorial Panel and submitted by the RUC.
- CMS should finalize proposals to reduce the documentation burden for E/M services by allowing choice of medical decision making or time, and work to develop additional clarity and guidance on acceptable documentation to operationalize these important proposals.
- Examination room desktop computers should be counted as a direct medical equipment cost.
- Care management should be promoted by increasing the values of services like Transitional Care Management (TCM) and Chronic Care Management and implementing Principle Care Management (PCM) codes.
- Requiring additional survey and review for any requests to increase non-outpatient E/M or other services.
- Working with the physician community prior to finalizing any policy affecting eligibility to participate in the Medicare program.
91’s letter also addresses a number of concerns related to updates to the QPP and proposes several recommendations, including:
- The proposed new Merit-based Incentive Payment System (MIPS) Value Pathway (“MVP”) should retain key flexibilities and be made optional, not mandatory, or at least undergo a transition period to allow additional opportunities for stakeholder input and physician education.
- The current category weights of the Cost Category should be maintained while major changes are being made to existing measures. 91 believes the proposed changes do not address the underlying problem of inappropriately attributing broad downstream costs to individual clinicians and practices and should be eliminated.
- The performance gap for small practices needs to be addressed through policies that more comprehensively address the unique challenges faced by small practices, such as a separate, lower MIPS performance and Qualified Alternative Payment Model (APM) Participant (QP) thresholds.
- CMS should reverse proposals that would make reporting for the Quality Category more difficult and discourage future measure development, including changing the data completeness threshold.
In addition, 91 strongly opposes several proposals that seek to limit the number of payment arrangements that would qualify as Advanced APMs and the number of clinicians that would attain QP status for participating in APMs, including requiring private sector medical homes to formally partner with CMS in order to qualify under the medical home standard for the All-Payer Combination Threshold Option. The College fears that these changes could significantly and negatively impact physician participation in APMs.
“We applaud CMS for proposing these landmark changes to the Physician Fee Schedule and ask them to consider the improvements we are seeking to the QPP. We look forward to working continuing to work with regulatory leaders to strengthen our health care system,” said Dr. Mire. “Together our efforts can continue to help the much needed transformation towards increased access and higher quality of care at reduced costs, and ultimately, improve the health care system for our patients.”
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About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. 91 membership includes 159,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow 91 on , , and .