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ACR Responds to CY2020 Medicare Physician Fee Schedule Proposed Rule

In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American College of Rheumatology (ACR) applauded a provision in the CY2020 Physician Fee Schedule proposed rule that would increase Medicare reimbursement for evaluation and management (E/M) services to more appropriately reflect the time and expertise these face-to-face services require. The ACR also urged CMS to make additional changes that would facilitate the delivery of high-quality rheumatology care.  

“We applaud CMS for taking steps to ensure rheumatologists and other cognitive specialists are adequately reimbursed for the time-intensive, high-value services they provide,” said Paula Marchetta, MD, MBA, president of the ACR. “These proposed changes will help ensure Medicare beneficiaries living with rheumatic disease can continue to receive the healthcare services they need and deserve.”  

The proposed changes to E/M coding represent a welcome reversal from a previous CMS proposal that would have significantly cut reimbursement for specialists who provide care to patients with complex conditions. According to a 2018 report from the Medicare Payment and Advisory Commission (MedPAC), healthcare services billed under E/M codes – which include examinations, disease diagnosis, risk assessments, and care coordination – are grossly under-compensated by Medicare. 

The new changes align with the American Medical Association’s recommendations that were developed in collaboration with the ACR and other organizations representing cognitive specialties.

The ACR also urged CMS to adopt a number of other changes in the final rule, including:

  • Clarify that proposed documentation reduction requirements take place in calendar year 2020. The proposed rule includes modifications to CMS’ documentation policy so that, for established patients, physicians and healthcare professionals are not required to document information in the provider’s note that is already present in a patient’s medical record. This change would greatly alleviate the paperwork burden on physicians and will enable them to focus more of their attention towards patients. The ACR is asking that CMS clarify that these changes take effect at the beginning of 2020 so that physicians can benefit from immediate relief.
  • Implement the Merit-based Incentive Payment System (MIPS) Value Pathway (MVP) program in a manner that is voluntary and based on measures that are meaningful to clinical care. The ACR expressed concerns about CMS’ intent to move forward with the new program without more robust vetting and stakeholder input. In particular, the ACR urged CMS to include, at a minimum, an opt-in policy for the potential MVP pilot program and reiterated its opposition to the agency’s proposal to layer population health of administrative claims-based measures into the MVP since they do not provide a granular enough level of information for physicians to make improvements in practice.
  • Reverse the removal of specific Qualified Clinical Data Registry Measures. The ACR believes that CMS’ plan to remove measures 178: Rheumatoid Arthritis: Function Status Assessment and 182: Functional Outcome Assessment would significantly undermine efforts to lay the necessary groundwork to establish additional rheumatology outcome measures. The ACR hopes to work with CMS on this issue before the rule is finalized.
  • Work with the Center for Medicare and Medicaid Innovation (CMMI) to adopt Alternative Payment Model (APM) options that would encourage more providers to participate in disease-specific Physician Focused APMs. The ACR notes that there are few APMs that are feasible for rheumatologists and that the current nominal risk criteria make it difficult for smaller practices to attempt the APM track.  The ACR is submitting its rheumatoid arthritis APM in the coming weeks and hopes that CMS and CMMI will consider expanding APM options for rheumatology professionals.

“The ACR remains dedicated to ensuring that rheumatologists and rheumatology interprofessional team members have the resources they need to work with CMS and provide patients with high-quality care,” Dr. Marchetta concluded. “In order to achieve those objectives, payment programs must be designed to reflect the way clinicians treat patients. We hope to continue serving as a resource to the agency as it moves forward with the rulemaking process.”

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