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AAMC Submits Comments on Proposed 2014 Medicare Physician Fee Schedule

September 13, 2013—The AAMC Sept. 6 submitted a comment letter  to the Centers for Medicare and Medicaid Services (CMS) on proposed changes in the Medicare Physician Fee Schedule Proposed Rule for CY 2014 [see Washington Highlights, July 12]. The letter outlines multiple concerns the AAMC has related to proposed changes to the Physician Quality Reporting System (PQRS) and Value-based Payment Modifier (value modifier or VM).

The AAMC also expresses its concerns on the proposed Investigational Device Exemption (IDE). The letter supports CMS’s continued efforts to recognize care coordination efforts through the proposed new codes for Complex Chronic Care Management Services. Finally, the letter addresses the proposed cuts to physician fees under the Sustainable Growth Rate (SGR).

The letter describes that AAMC appreciates CMS’s efforts to advance the PQRS and VM programs, but is concerned about the complexity of participating in the program, its alignment with other programs such as the Electronic Health Record (EHR) incentive program, and the measures used to grade performance. The AAMC commented that CMS should delay full implementation of pay-for-performance until the agency can assure the accuracy and consistency of performance scoring.  Groups should have the opportunity to understand and improve performance before moving to full pay-for -performance.

As feedback reports on cost performance first become available in mid-September, the letter argues that groups do not have sufficient time to analyze data and develop improvement strategies before the performance period begins. In addition, AAMC notes that no measures should be introduced into a pay-for-performance program such as the VM without providers having at least one year to test and offer feedback on the measure. The AAMC also recommends CMS remove the Medicare Spending per Beneficiary (MSPB) measure from the VM, as its attribution methodology is designed for hospital cost measurement.

As proposed, quality-tiering in the VM would be mandatory beginning in calendar year (CY) 2016, with an increase in the amount at-risk from negative 1 percent to negative 2 percent. The AAMC commented that CMS should delay mandatory quality-tiering at least one more year. Pay-for-performance should not become mandatory until CMS has validated that national benchmarks for cost and quality are comparable for individuals, groups, and across the various reporting mechanisms. AAMC also commented that CMS should not increase the amount at-risk for quality-tiering.

AAMC supports CMS’s proposal to pay for care coordination management services for complex patients with multiple chronic conditions. However, the requirements of the proposed new codes “are too administratively difficult to implement” by providers and groups.

The AAMC commented that it appreciates CMS’s efforts to centralize the IDE coverage process. However, the AAMC is concerned that the proposal will severely limit the ability of beneficiaries to participate in clinical trials. The AAMC also expressed its concern about whether CMS has sufficient staff expertise to evaluate clinical trial studies in a timely manner.

The AAMC remains concerned with the projected negative updates to physician fees under the SGR and supports a full repeal. The association encourages CMS to work with Congress to revise the physician payment formula so that physicians no longer will have to face the potential prospects of an annual negative update.


Mary Patton Wheatley, M.S.
Director, Health Care Affairs
Telephone: 202-862-6297

Evan Collins, MHA
Specialist, Clinical Operations and Policy
Telephone: 202-828-0552


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
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Telephone: 202-903-0806