Internists Encouraged by a Number of Policies in Proposed Medicare Rules

WASHINGTON, D.C. July 14, 2021 –The American College of Physicians (ACP) is encouraged by many of the provisions that were included in the proposed 2022 Medicare Physician Fee Schedule and Quality Payment Program (QPP) rules that were released by the Centers for Medicare and Medicaid Services (CMS) yesterday. ACP specifically called attention to policies on telehealth, on increasing health equity and those that would make the QPP better for physicians. ACP also noted that while there are promising provisions in the rules, that the Fee Schedule also includes a significant cut to physician payments in 2022.

“ACP is glad to see that the proposed rule extends some of the services and increased flexibility for telehealth through the end of 2023,” said George M. Abraham, MD, MPH, FACP, FIDSA, president, ACP. “The stability of knowing those services will continue is important for the physicians who provide them.  This also better allows CMS to study the services and will inform future policies on telehealth to make sure they work for patients and physicians.”

One of the telehealth changes included in the rule would allow for some of the audio-only services that were allowed during the COVID-19 public health emergency (PHE) to continue, however it would only apply to behavioral health services.

“ACP is extremely supportive of continuing to allow audio-only services. Since the beginning of the COVID-19 pandemic we have repeatedly called attention to the need for patients to be able to access care by phone. However, we believe that because audio-only telehealth is an important component tool for physicians to improve health equity and patient access it should not be limited to only patients seeking behavioral health services,” continued Dr. Abraham. “We are asking CMS to broaden the flexibility and continue to allow other evaluation and management (E/M) services to be provided using audio-only communication.”

ACP also noted a provision in the Fee Schedule that calls for the agency to begin collecting additional data on health equity issues to analyze disparities that occur across their programs.

“ACP is encouraged to see CMS interest in advancing health equity for people with Medicare while protecting individual privacy,” said Dr. Abraham. “Access to health equity data may enable a more comprehensive assessment of health equity and support initiatives to close the equity gap.”

Dr. Abraham further noted that it would be important to make sure that CMS designed the data collection in a way that would not place undue burden on physicians or their practices.

In the proposed QPP rule, ACP noted that they were glad to see the CMS is going to include a chronic care management as one of the seven MIPS Value Pathways (MVPs) for 2023.

“ACP had proposed a similar MVP concept to CMS, and we will be reviewing closely to see how CMS’s proposal aligns with ours. We are glad to see that the agency understands the benefit that chronic care management can provide patients and the importance of payment models that account for it,” said Dr. Abraham. “We hope that it can be a useful option for our members seeking some relief from the burdens of the current MIPS program structure.”

The QPP rule also included provisions that would relax some of the reporting requirements for Accountable Care Organizations (ACOs) under the Medicare Shared Savings Program to give them more time to implement changes.  ACP is glad to see these changes respond to concerns raised by ACOs and acknowledge the commitment those organizations have to providing the highest quality care and improving patient outcomes while also delivering this care in the most cost-efficient manner.

Lastly, ACP calls attention to the across-the-board cuts to physician payments that would occur in 2022 and the need for additional action to prevent the cuts. The proposed cuts are the result of a reduction that is necessary to keep Medicare payments budget neutral. At the end of 2020, Congress stepped in to pass a one-year fix that prevented cuts that were due to take effect in 2021. Without additional action the cuts will go into effect on Jan 1, 2022.

“We have seen demonstrated over the past year and half why it is critical for Americans to have access to necessary health care. We need to ensure that practices across the country are able to continue to operate and provide frontline care that improves health equity and patient access in their communities,” concluded Dr. Abraham. “While CMS does not have the authority on their own to correct this, we ask them to support efforts to fix the problem through Congress. It is critically important for the administration and Congress to work together to prevent these cuts and ensure stability for patients and their physicians.”


About the American College of Physicians

The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 161,000 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, Facebook, and Instagram.

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