Internists tell CMS not to proceed with changes to payments for E/M services

September 10, 2018, American College of Physicians

Proposed changes to payments for evaluation and management (E/M) codes do not appropriately recognize the value of cognitive care required to treat complex patients, and the proposal should not be implemented, says the American College of Physicians (ACP). The changes are part of the proposed 2019 Medicare Fee Schedule (MFS) and Quality Payment Program (QPP) rules. In comments to the agency, ACP noted that while they are supportive of the proposal to reduce documentation burden for E/M services—something that ACP has been asking CMS to address for several years—that those improvements should not be contingent on acceptance of the payment changes, and CMS should take the time to work with physicians to "get it right," rather than hastily imposing an arbitrary deadline next summer.

"ACP recognizes key improvements the proposed rule makes in reducing documentation burdens for E/M services that are aligned with our Patients Before Paperwork initiative, however, we believe that the proposal to pay the same for complex cognitive care as more basic care will undermine patients who need our help the most," said Dr. Ana María López, MD, MPH, FACP, president, ACP. "As proposed, a considerable number of physicians would be disadvantaged if they treat patients who are frail, sick, or more complex, and would be discouraged from spending time with them."

ACP's comments to the agency were part of a letter submitted today to CMS Administrator Seema Verma and signed by Dr. Jacqueline Fincher, MD, MACP, chair of ACP's Medical Practice and Quality Committee. In addition to discussing the proposed changes to E/M codes, the letter included ACP's full set of recommendations and concerns on the proposed rules for the 2019 fee schedule and QPP, as well as recommendations on alternatives, in lieu of CMS's flat fee proposals.

"ACP believes that CMS should work with the physician community to consider alternative solutions that would ease documentation burdens, but restructure how E/M services are paid. Documentation reduction is instrumental in addressing concerns physicians across the country face, including EHRs and note bloat," said Dr. López. "ACP is open to developing and pilot-testing blended payment alternatives, if they allow for differentiation in payment rates so that more complex E/M services are paid more than less complex ones, and simplify documentation requirements while addressing CMS's program integrity concerns."

Among the additional issues covered in the letter, ACP recommended:

  • Several improvements to the Merit-based Incentive Payment System (MIPS): Reducing administrative burden in MIPS; reducing MIPS complexity, including streamlining scoring across categories; increasing program flexibility; and maximizing MIPS participation, including finalizing the proposed "opt-in" option for those currently excluded under the low-volume threshold.
  • Continuing a gradual MIPS implementation approach by not increasing the weight of the Cost Category as new measures are introduced nor doubling the MIPS performance threshold based on non-MIPS data.
  • Allowing for a more gradual implementation of 2015 Certified EHR Technology (CEHRT).
  • Avoiding low-reliability measures in selecting measures for the Quality Performance Category of MIPS, including the proposed episode-based cost measures.
  • Providing more opportunities for small and rural practices to succeed under QPP.Supporting implementation on January 1 of proposals to pay for virtual visits and other non-face-to-face cognitive services.

"We encourage CMS to take into consideration the comments that ACP and other physician organizations will be submitting as the agency finalizes these rules, in particular their proposed changes to E/M codes," said Dr. López. "We want to work with CMS toward a plan that would reduce E/M documentation burdens while preserving appropriate payment levels for more complex cognitive care."

Explore further: Internists encouraged by payment rules from CMS, note key areas of concern

Related Stories

Internists encouraged by payment rules from CMS, note key areas of concern

November 4, 2017
The American College of Physicians (ACP), expressed support for some of the provisions included in the final rules for the Medicare Physician Fee Schedule and the Quality Payment Program (QPP) for 2018, and noted some areas ...

ACR acknowledges CMS efforts to increase flexibility and reduce regulatory burdens

June 22, 2017
The American College of Rheumatology (ACR) today welcomed components of a new proposed rule from the Centers for Medicare & Medicaid Services (CMS) regarding the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) ...

ACP's initial review of QPP proposed rule 'encouraging'

June 21, 2017
The American College of Physicians (ACP) is encouraged that the 2018 proposed rule to implement the Quality Payment Program (QPP), released yesterday by the Centers for Medicare and Medicaid Services (CMS), continues to take ...

MACRA changes government approach to doctor payment

April 9, 2017
(HealthDay)—Implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) has made fundamental changes to the government's approach to physician payment, according to a March 27 policy brief published in Health ...

Report examines MACRA's impact on radiologists

December 28, 2016
A new Harvey L. Neiman Health Policy Institute series of reports explores the impact of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, along with the Centers for Medicare and Medicaid Services' (CMS) 2016 ...

AAFP: Expected 0.5 percent pay increase reduced to zero

November 18, 2015
(HealthDay)—A small but promised Medicare pay increase has effectively been reduced to zero for all physician specialties, according to the final 2016 Medicare physician fee schedule and a report published by the American ...

Recommended for you

Self-lubricating latex could boost condom use: study

October 17, 2018
A perpetually unctuous, self-lubricating latex developed by a team of scientists in Boston could boost the use of condoms, they reported Wednesday in the journal Royal Society Open Science.

How healthy will we be in 2040?

October 17, 2018
A new scientific study of forecasts and alternative scenarios for life expectancy and major causes of death in 2040 shows all countries are likely to experience at least a slight increase in lifespans. In contrast, one scenario ...

Study finds evidence of intergenerational transmission of trauma among ex-POWs from the Civil War

October 16, 2018
A trio of researchers affiliated with the National Bureau of Economic Research has found evidence that suggests men who were traumatized while POWs during the U.S. Civil War transmitted that trauma to their offspring—many ...

Father's nicotine use can cause cognitive problems in children and grandchildren

October 16, 2018
A father's exposure to nicotine may cause cognitive deficits in his children and even grandchildren, according to a study in mice publishing on October 16 in the open-access journal PLOS Biology by Pradeep Bhide of Florida ...

Many supplements contain unapproved, dangerous ingredients: study

October 13, 2018
(HealthDay)—U.S. health officials have issued more than 700 warnings during the last decade about the sale of dietary supplements that contain unapproved and potentially dangerous drug ingredients, new research reveals.

Age at which women experience their first period is linked to their sons' age at puberty

October 12, 2018
The age at which young women experience their first menstrual bleeding is linked to the age at which their sons start puberty, according to the largest study to investigate this association in both sons and daughters.

0 comments

Please sign in to add a comment. Registration is free, and takes less than a minute. Read more

Click here to reset your password.
Sign in to get notified via email when new comments are made.