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AAMC Submits Comments on Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule

September 27, 2019

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PRESS CONTACTS
Gayle Lee, Director, Physician Payment & Quality
Kate Ogden, Physician Payment & Quality Specialist

The AAMC Sept. 26 submitted comments in response to the calendar year (CY) 2020 Medicare Physician Fee Schedule and Quality Payment Program proposed rule.  

Notably, the AAMC supports CMS’ proposal in the rule to retain separate payment rates for evaluation and management (E/M) code levels in 2021 instead of implementing a blended payment rate and to finalize a policy that would allow physicians to select a level and document based on either medical decision-making or time.

While the AAMC supports the increase in payment for E/M services, the association raises concerns about the potential reductions in payment for some specialties that result from implementing the updated valued for the office E/M codes. The AAMC urges CMS to work with the medical community to encourage Congress to replace payment freezes with positive annual updates to not only offset the impact of the increases to the office visits but to recognize inflationary pressures.

While the AAMC expresses appreciation for CMS’ proposal to develop a new pathway under the Merit-based Incentive Payment System (MIPS) program (referred to as MIPS Value Pathways), the AAMC comments that CMS should ensure that participation in the program is voluntary, especially at a time when providers are experiencing numerous other significant changes.

Additional recommendations from the AAMC include the following:

Physician Fee Schedule: 

  • Add-On Code: CMS should postpone implementation of the add-on code until there is further clarification provided on how it would be used and what the impact would be on payment and redistributions among specialties.
  • Global Surgical Codes: Values for codes with global periods in which office visits are included in the service should be adjusted to reflect the new E/M values recommended for office visits.
  • Medical Record Documentation/Verification: CMS should allow physicians, physician assistants, and Advanced Practice Registered Nurses who document and who are paid under the PFS for their professional services to review and verify (sign and date) rather than redocument notes made in the medical record by other physicians, residents, nurses, students, and members of the medical team.
  • Principal Care Management Code: CMS should finalize its proposal to establish a new code for principal care management services. Physicians spend a significant amount of time managing the care of patients with a single serious condition, just as they do for patients with chronic conditions, and should be reimbursed for this work. 
  • Interprofessional Consult Code and Verbal Consent: To address the need for patient consent in a way that is practical for providers and practices, and to minimize inefficiencies and confusion for beneficiaries, the AAMC urges CMS to allow providers and to obtain blanket consent at the practice level for this service on at least an annual basis.
  • Medicare Shared Savings Program (MSSP): CMS should not change the quality scoring methodology for MSSP at a time when accountable care organizations are experiencing a major redesign of the MSSP program under the “Pathways to Success” program.

Quality Payment Program:

  • MIPS Value Pathways (MVPs): Instead of assigning clinicians to MVPs, CMS should allow physicians to opt-in to CMS’ suggested MVP, choose an alternative MVP, or continue to report measures through the traditional MIPS program.
  • MVPs and Large Multi-Specialty Practices: With the large number of distinct specialties reporting under one taxpayer identification number in academic medical centers, it would be very challenging to identify MVPs that would be meaningful for all the different specialties in the practice. A better solution would be to have subgroup identifiers that allow measurement of the performance at the subgroup level.
  • Cost Category: Given the multiple undetermined factors under the cost category, including the need for risk adjustment, the need for better attribution methodologies, and further development of episode groups, the AAMC strongly urges CMS to maintain the weight of the cost category at 15% instead of increasing it to 20%. In future MIPS feedback reports, CMS should provide additional details in the cost category.
  • Risk Adjustment: As appropriate, CMS should risk-adjust outcome, population-based measures, and cost measures for clinical complexity and sociodemographic factors.
  • Improvement Activities: CMS should maintain the existing participating clinician threshold for improvement activities. CMS should not adopt a policy that would require 50% of the national provider identifiers to perform the same improvement activity for 90 continuous days. Setting such a high threshold could force physicians to participate in an improvement activity that has no relevance in the field in which they are providing care and discourage participation in improvement activities that are meaningful.
  • Advanced Alternative Payment Models: CMS should support any Congressional efforts that would give the agency the discretion to set the thresholds to be qualified participants in an advanced APM at an appropriate level to encourage AAPM participation. The AAMC also encourages CMS to support efforts by the medical community to urge Congress to extend the 5% bonus beyond 2024.

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