Medicare Fee Schedule and Quality Payment Program Changes Elicit Mixed Review from ACP

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Some moves reflect ACP priorities, but others fall short of hoped-for change

Dec. 7, 2018 (ACP) – Changes to the rules that govern reimbursement to physicians for treating Medicare patients in 2019 have been met with a mix of encouragement and reservation by the American College of Physicians. The Nov. 16 issue of the ACP Advocate detailed changes to evaluation and management services. However, the rules contained other changes important to internists.

“We are pleased that the Centers for Medicare and Medicaid Services (CMS) has heard our concerns regarding the fee schedule and Quality Payment Program,” said Brian Outland, ACP's director of regulatory affairs. “CMS didn't go as far as we would have hoped in some areas, but they did make some changes in response to our comments. As a result, burdens on medical office staffs will be reduced in 2019.”

Specifically, ACP is pleased about the willingness of CMS to make adjustments in certain areas of the fee schedule:

  • In line with ACP priorities, CMS is not moving forward with proposals to implement the Multiple Procedure Payment Reduction (MPPR).
  • New codes for non-face-to-face visits – such as virtual check-ins, e-consultations and remote evaluation of patient images and videos – will be implemented in 2019. ACP believes this change will improve patient access to care and help control costs.
  • Revisions to the Physician Practice Expense Information Survey (PPIS), a longtime ACP priority, may be on the way: The PPIS is a multispecialty, nationally representative, practice expense survey of both physicians and non-physician practitioners paid under the physician fee schedule. PPIS data includes administrative labor, office expense, and all other expenses used in developing the practice expense portion of relative value units that are used to calculate payments. Therefore, changes to the PPIS are expected to help improve payment accuracy for physicians.

As for the final Quality Payment Program rule for 2019, ACP is pleased by some changes but will continue to encourage CMS to do more:

  • ACP has a positive reaction to the CMS decision to continue the consistent risk threshold for Alternative Payment Models (APMs), which ACP believes will provide consistency and predictability for model developers and help APMs continue to grow.
  • As ACP had requested, CMS agreed to provide a Merit-based Incentive Payment System (MIPS) opt-in option for practices previously excluded under the low-volume threshold – a move that ACP believes will expand participation without increasing burden.
  • ACP also supports the 2015 Certified Electronic Health Record Technology (CEHRT) requirement and agrees that using updated standards and functionality can help improve interoperability.
    • However, ACP is disappointed that CMS did not emphasize the need to provide flexibility to physicians as practices implement these upgrades in 2019. The College maintains that rushing implementation of these upgrades to meet a reporting deadline could have serious patient safety risks, as well as being a major expense and burden, particularly to small practices.

“This is one of the areas where we have concerns,” Outland said.

Another concern the College has is about the finalized changes to the cost category. These include adding several new episode-based measures, despite concerns over low reliability ratings, while simultaneously increasing the weight of the cost category from 10 to 15 percent, despite objections from ACP and other stakeholders.

“We are concerned that practices won't be ready for this, and it may negatively affect some of them going forward,” Outland said. ACP believes that clinicians should not have their MIPS scores negatively impacted by inaccurate measures.

Moving forward, Dr. Ana María López, ACP's president, said that the College “will continue to advocate on behalf of the patient care that internal medicine specialists provide to ensure they are adequately valued for their instrumental role in driving high-value care and will look for continual reforms to the Quality Payment Program to maximize positive patient outcomes while minimizing clinician burdens.”

More Information

Details on changes to the Physician Fee Schedule for evaluation and management (E/M) services, and ACP's reaction to those changes, were the focus of an article, “Medicare Postpones Changes in Pay for Patient Evaluation and Management Services,” in the Nov. 16 Advocate.

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Back to the December 07, 2018 issue of ACP Advocate