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AAMC Responds to 2015 Medicare Physician Fee Schedule Proposed Rule; Opposes Proposal to Increase the Physician Value Modifier

September 5, 2014— The AAMC Sept. 2 submitted comments  to the Centers for Medicare and Medicaid Services (CMS) on the 2015 Physician Fee Schedule proposed rule. [See Washington Highlights, July 11]  In its letter, AAMC opposes the proposal to double the amount at risk for the pay-for-performance program, the Value-Based Payment Modifier (VM), and provides a series of recommendations to improve that program as well as the pay-for-reporting program, Physician Quality Reporting System (PQRS). 

The letter also addresses proposals related to the Open Payments “Sunshine Act” database [see related story]. The letter includes responses to other payment issues, the Medicare Shared Savings Program, and a broad request from the Centers for Medicare and Medicaid Innovation (CMMI) to evaluate new delivery models.

The AAMC letter opposes the proposal to increase the amount at risk for performance in the VM from negative 2 percent to negative 4 percent. If proposals are finalized, up to 9 percent of a practice’s Medicare payments in 2017 depend on satisfactory PQRS reporting, successful attestation of the Medicare/Medicaid Electronic Health Record (EHR) Incentive Program, and performance in the VM in 2015. 

The AAMC argues the “acceleration is premature” given the numerous changes to the PQRS and VM programs and the CMS and providers cannot estimate performance.

Also related to PQRS and the VM, the AAMC recommends CMS provide feedback to providers before the performance period begins (similar to the Hospital Value-Based Purchasing Program); not finalize proposals to change the current cost measures; and stabilize the PQRS reporting options and provide a transition period for new changes.

Other priority recommendations in the AAMC letter include:

  • Supporting the addition of an improvement score in quality performance for the Medicare Shared Savings Program (MSSP);

  • Opposing a blanket request from CMMI to collect patient level data for program evaluation purposes and instead requesting CMMI work with stakeholders and the Office of Civil Rights to identify a targeted list of elements on a program-by-program basis that meets program needs and complies with HIPAA; 

  • Requesting a delay in implementation for off-campus data collection;

  • Supporting changes to the new management code for chronic care management, while noting concern about administrative complexity;

  • Opposing a proposal to transition 10- and 90-day global codes to 0-day global codes in 2017 and 2018; and

  • Requesting CMS adopt a new protocol for reviewing new and revised service codes


Len Marquez
Director, Government Relations
Telephone: 202-862-6281


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