ACP Submits Recommendations on 2018 Physician Fee Schedule Proposal

(Washington, September 11, 2017) The American College of Physicians (ACP) today provided more than a dozen recommendations on the proposed rule for the calendar year 2018 Medicare Physician Fee Schedule (PFS) to the Centers for Medicare and Medicaid Services (CMS). ACP’s recommendations encourage CMS to further align the various Medicare reporting programs and continue the Agency’s goals to reduce the administrative burdens physicians face on a daily basis – allowing physicians to refocus their time on putting patients first and providing high-value care.  ACP’s priority recommendations include:

Evaluation & Management (E/M) Documentation Reform: ACP is very encouraged to see that CMS recognizes the administrative burden associated with the E/M documentation guidelines and is open to revisions.  Documentation must be about the care of the patient and advancing the patient’s care from one visit to the next. ACP provided detailed recommendations for E/M documentation reform and looks forward to working with CMS and other stakeholders on the revision of the E/M documentation guidelines.

Further Refinement of Care Management Services Codes: ACP applauds CMS for continuing to reduce the burdens associated with the care management services code set and provided a list of recommendations specific to Chronic Care Management to promote enrollment in the important program, reduce administrative burden, and align coding requirements between CMS and Current Procedural Terminology (CPT) guidance.

Appropriate Use Criteria for Advanced Diagnostic Imaging Services: ACP supports a delay in implementation of the Appropriate Use Criteria for advanced diagnostic imaging services until 2019 and encourages CMS to initially implement the program on a smaller scale such as a pilot to allow an evaluation to occur before it is expanded.

Alignment of Legacy Reporting Programs with the Quality Payment Program: ACP appreciates the proposals to align the policies for the legacy reporting programs with those that will be in place in the Merit-Based Incentive Payment System (MIPS) and further encourages CMS to reduce or eliminate the penalties associated with these programs consistent with the MIPS transition year "Pick Your Pace" policies.

ACP also provided detailed payment policy updates to address the overall physician payment update and practice expense calculations as well as a four-part response to CMS’ Request for Information on Reducing Regulatory and Administrative Burden in the Medicare Program, among many other recommendations.

“As a practicing primary care internist, I am greatly encouraged that CMS is proposing substantial improvements to help me and my colleagues provide coordinated, patient-centered, high value and team-based care to our patients” said Jacqueline W. Fincher, MD, MACP, chair of ACP’s Medical Practice and Quality Committee (MPQC).  “We look forward to providing CMS with detailed comments to support these improvements while recommending other changes to strengthen primary care.”


The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 152,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter and Facebook.

Contact: David B. Kinsman, APR, 202-261-4554,