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AAMC Responds to CMS Physician Fee Schedule 2018 Proposed Rule

September 15, 2017—The AAMC Sept. 11 submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the physician fee schedule 2018 proposed rule.  The annual physician fee schedule rule updates physician payment rates and policies under the Medicare program. 

Most notably, the AAMC made the following key recommendations: 

  • Do not make a 75% reduction in hospital outpatient department (HOPD) reimbursement for non-excepted services provided at off campus outpatient hospital departments. This proposed reduction in payment is based on insufficient data and would set rates well below hospital cost of providing care
  • Finalize the proposal to delay implementation of the Appropriate Use Criteria (AUC) consultation requirement until Jan. 1, 2018, at the earliest

  • Finalize the proposal to delay the requirement that patient relationship codes and modifiers be reported on the claim form

  • Focus efforts on revising the evaluation and management guidelines, particularly the history and physician examination requirements to reduce burden

  • Expand coverage for telehealth services by changing requirements regarding the originating site and rural location of services

  • Provide coverage and payment for consultations between primary care physicians and specialists

In addition, AAMC applauded the invitation to comment on ideas for regulatory relief to improve the health care system by reducing burden.

A final rule will be issued by Nov. 1, 2017, and many of the provisions in the rule will be implemented Jan. 1, 2018.


Gayle Lee
Director, Physician Payment & Quality
Telephone: 202-741-6429


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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
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806