Internal Medicine Physicians Pleased With Proposed Rule to Improve Medicare Payments

Point to CMS responsiveness to concerns about regulatory and administrative burdens, and other proposals

(Washington – July 18, 2017) The American College of Physicians (ACP) today noted they are pleased with the 2018 Physician Fee Schedule proposed rule released last week by the Centers for Medicare & Medicaid Services (CMS).

CMS agreed with a long-identified need for reducing administrative tasks as an important objective, maintaining significant policy and participating in many efforts to this effect.  With this goal in mind, ACP developed the “Patients Before Paperwork” initiative in 2015 with the intent of reinvigorating the patient-physician relationship by challenging unnecessary practice burdens.  As part of this initiative, this year the College published a position paper, “Putting Patients First by Reducing Administrative Tasks in Health Care,” in Annals of Internal Medicine.   

ACP noted “wins” in CMS proposals, too:

Evaluation and Management (E/M) Comment Solicitation: ACP has met with various officials within the Department of Health and Human Services (HHS) regarding the current E/M documentation guidelines and the administrative burdens they impose on clinicians. The comments and request for information by CMS are responsive to these concerns. ACP is very encouraged to see that CMS recognizes the administrative burden associated with the documentation guidelines and is open to revisions.

Documentation must be about the care of the patient; advancing the patient’s care from one visit to the next, ACP believes.  Clinicians should be able to capitalize on the advancing technology of electronic health records (EHRs) without having to duplicate documentation previously captured elsewhere within the patient record.

Value-Based Payment Modifier (VM): CMS proposes to reduce the potential penalties associated with the VM program for the 2016 performance period and hold harmless from downward adjustments those physicians who satisfy quality reporting requirements. This is in line with previous requests from ACP that CMS reduce the penalties associated with the legacy reporting programs and align them with the first year of the Merit-Based Incentive Payment System (MIPS) under the Quality Payment Program (QPP).

Physician Quality Reporting System (PQRS): CMS proposes to change the satisfactory reporting criteria for the 2016 PQRS program to be in line with the six-measure quality reporting requirements for MIPS rather than the nine measures across three domains previously required in PQRS. This will allow some physicians who attempted to report for the 2016 performance period to avoid penalties and better align PQRS with MIPS as physicians transition to QPP.

Overall Payment Update and Misvalued Code Target: ACP is pleased to see a marginal increase of the conversion factor. However, ACP would prefer to see CMS achieve the full misvalued code target so there is not an across-the-board reduction in the fee schedule.

“As a practicing primary care internist myself, 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 Jack Ende, MD, MACP, ACP president.  “We look forward to providing CMS with detailed comments to support these improvements while recommending other changes to strengthen primary care.”


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


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.