Internists Express Support for Goals of Energy and Commerce Committee Legislative Proposal to Repeal Sustainable Growth Rate, Suggest Improvements

American College of Physicians response letter provides feedback on specific questions raised in the legislative language and recommendations for moving forward

June 10, 2013

(Washington) - The American College of Physicians (ACP) today sent a letter to the Energy and Commerce Committee (E&C) providing feedback on legislative language that the committee released on May 28, meant to repeal the Sustainable Growth Rate (SGR) formula used for calculating Medicare payments to physicians and replace it with a fair and stable system.

The 20-page letter provides recommendations on questions that the committee raised on the two phases. The first phase of the legislation would stabilize the payment rates under the current system while setting up the move to new payment models. The second phase would then transition away from fee-for-service and toward value-based models of payment with an update incentive program.

ACP said that the legislation should:

  • Provide positive and stable payments to all physicians, with higher baseline updates for evaluation and management services, for at least five years;
  • Create a process for physicians to qualify for graduated incentive-based payments during this period of stability for participating in programs to improve quality and the effectiveness of care;
  • Put greater emphasis on programs that would move away from reporting on process measures at the individual physician level to programs that measure improvements in outcomes and patient experience with care at the organizational and system level;
  • Create a process to "deem" programs that would qualify for graduated incentive based payments;
  • Create a clearer "bridge" between the draft bill's proposed fee-for-service competency-based incentive program and new payment models, by creating incentives within the competency-based update program for physicians who are developing the competencies needed, within their practices and organizations, to successfully make the transition to new payment and delivery models aligned with value;
  • Create incentives for physicians to develop and participate in "peer cohorts" that have the greatest potential to improve outcomes, patient experience, and effectiveness of the care provided, at both an individual and organizational level and within their own communities;
  • Allow physicians in recognized PCMH practices to qualify for higher FFS payments as early as next year; and
  • Create a timeline and process for HHS to evaluate, propose, and designate approved new payment and delivery models, with hardship exemptions.

Additionally, the College suggested that the committee needed to include additional, alternative payment models that could be considered for incorporation in a new Medicare system after the SGR repeal. These models should include the Patient-Centered Medical Home (PCMH) and PCMH Neighborhood; the "Prometheus" Evidence-informed Case Rate (ECR) model; the Comprehensive Global Payment model; and the expanded use of bundled payments. Lastly, the College acknowledged that there may be some physicians who would be unable to transition away from the fee-for-service model of payment and that provisions for a hardship exemption needed to made for those who could not through no fault of their own.

Molly Cooke, MD, FACP, president of ACP, ended the letter by saying that the College appreciates the opportunity to share its recommendations with the committee. "We support the intent of your proposal, and hope that our responses to the questions you posed will be of help to you in continuing the development of a proposal," she concluded.


The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 133,000 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.

David Kinsman, (202) 261-4554
Jacquelyn Blaser, (202) 261-4572