Feedback Floods in on CMS’ Proposed Physician Fee Schedule

Debra Shute, September 12, 2017

MGMA, AMGA, and ACP comments urge reduction of administrative burden for providers treating Medicare beneficiaries in 2018.

Stakeholders had until yesterday to submit comments on the Centers for Medicare & Medicaid Services’ (CMS) Proposed Rule for the Calendar Year 2018 Medicare Physician Fee Schedule (PFS).

Physician advocacy groups including the American Medical Group Association (AMGA), the Medical Group Management Association (MGMA), and the American College of Physicians (ACP) have submitted their feedback in the form of a letter to CMS Administrator Seema Verma.

Related: Regulatory Burden on Medical Groups Excessive, MGMA Says

The groups offered numerous recommendations, including but not limited to the following key areas.

Evaluation and Management (E/M) Guidelines

CMS has proposed a multi-year effort to update the guidelines, reduce the administrative burden on physician practices, and better align E/M coding and documentation with the current practice of medicine.

To that end, current use of E/M complexity levels and their commensurate volumes of documentation are not necessarily conducive to delivering care that is high quality and time efficient, noted the AMGA.

“Documentation requirements should align and support reimbursement. That is, documentation requirements under FFS should not and cannot be the same as under value based arrangements if we expect these arrangements to succeed,” wrote Ryan O’Connor, AMGA’s interim president and chief executive officer.

“Documentation under value based arrangements should provide the necessary information to allow the primary provider and all other crosscovering providers to treat the patient longitudinally,” O’Connor continued.

The ACP agreed that E/M guidelines are outdated, yet stated that, “documentation of history and physical exam should continue to be a key component of the patient visit but they should not be associated with the auditing requirements.”

The MGMA, meanwhile, expressed support of simplifying the 1995 and 1997 guidelines but cited concerns about moving to a time-based approach to E/M billing.

“Although there is ample room to reduce paperwork that does not move the needle on high-quality healthcare and reduce the administrative complexity of billing these services, we caution against using this initiative simply as a disguised means to reduce reimbursement for physicians.”

Physician Quality Reporting Criteria

CMS is proposing for 2018 (the final PQRS payment year) to reduce the number of quality measures reported from nine to six, retrospectively to align with the requirement that eligible clinicians under the Medicare Access and CHIP Reauthorization Act’s (MACRA) Merit-based Incentive Payment System (MIPS) report six quality measures.

CMS also is proposing to make the Consumer Assessment of Health Plans (CAHPS) survey for PQRS optional under CMS web interface reporting for practices 100 or more in 2016.

Related: MACRA Needs More Work, Groups Say

Overall, groups supported the idea of easing the transition between old and new programs, but questioned the implications of reducing the number of quality measures retroactively.

“Reducing the requirements after the performance period has already concluded has the potential to create even more confusion for practices struggling to navigate the rules and payment implications of these retired programs, while simultaneously familiarizing themselves with and executing new MIPS reporting protocols,” the MGMA stated. “To be successful in MIPS, practices need to have their full attention committed towards meeting this end, and juggling current MIPS requirements while processing retroactive reporting requirements and how they impact their practice may create needless frustration and significant confusion.”

The AMGA also opposed the proposals, which O’Connor stated would “have the de facto effect of penalizing those providers that fully and faithfully participated in these programs and rewarding those that did not.”

The ACP, meanwhile, encouraged CMS to “allow any clinician who submitted any PQRS data for 2016 to be held harmless from any downward adjustments associated with PQRS and the VM for the 2016 performance period.” 

Debra Shute

Debra Shute is the Senior Physicians Editor for HealthLeaders Media.

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