ACP Pleased With E/M Changes in Proposed Fee Schedule, but Says More Support Needed

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ACP submitted recommendations for changes to the proposed 2021 Physician Fee Schedule

Oct. 23, 2020 (ACP) – While the American College of Physicians strongly supports needed changes to Evaluation and Management (E/M) requirements and payments in the 2021 Medicare Physician Fee Schedule, the College is firmly calling on federal officials to provide additional support to physicians.

ACP supports the efforts of the Centers for Medicare and Medicaid Services (CMS) “to make things easier for America's frontline physicians in the wake of the COVID-19 public health crisis,” said Dr. Ryan Mire, chair of the ACP Medical Practice and Quality Committee. “However, more needs to be done to ensure that our physician practices are able to weather the crisis. We will continue to work with CMS to find ways to support physicians and reduce burden so practices can focus their resources on treating their patients.”

In a 52-page Oct. 2 letter to Seema Verma, administrator of CMS, ACP makes a series of recommendations about changes that should be made to the 2021 Physician Fee Schedule.

“ACP highlighted a number of concerns that were not directly addressed by the CMS proposed rule, such as reimbursement for telephone calls and telehealth flexibilities that should be extended,” said Brian Outland, ACP director of regulatory affairs. “The COVID-19 pandemic has upended traditional physician workflows in so many ways that it is vital that these changes be addressed in a manner that allows physicians and their teams to adapt to this new reality.”

Specifically, ACP calls for the following changes, among others:

  • ACP strongly recommends that CMS use its administrative authority during the COVID-19 Public Health Emergency (PHE) to waive budget neutrality for contract year 2021 to ensure that physicians in every specialty, including internal medicine, will not be subject to reduced payments at a time when they are still facing significant challenges due to the ongoing pandemic. However, it is critical that any waiving of budget neutrality not delay or undermine the CMS decision to fully implement the E/M increases and other improvements on Jan. 1, 2021.
  • ACP strongly supports the GPC1X add-on code for visit complexity. However, ACP recommends that no more than 23% of estimated claims be the appropriate utilization estimate for this add-on code, rather than the 75% estimate from CMS. This change would reflect a more accurate expected usage of this code and would help mitigate any negative impact of budget neutrality, should it be allowed to take effect.
  • ACP strongly encourages CMS to consider extending several policies put in place during the COVID-19 PHE to address the barriers to patient access and physician adoption and use of telehealth and telephone services. ACP strongly recommends that CMS maintain pay parity between telephone E/M claims and in-person E/M visits and between all telehealth and in-person visits even after the PHE is lifted. ACP also recommends that CMS permanently extend the policy to waive geographical and originating-site restrictions after the conclusion of the PHE.

“These changes will greatly benefit internists who have had to change their workflows since the pandemic to enable them to meet patients where they are,” Outland said. “Internal medicine has long been undervalued, so these changes are a great step forward that will provide physicians with the resources they need to care for their patients.”

What's next? “We are currently in the rulemaking phase,” Outland said. “Before Oct. 5, we were in the proposed rule phase. In November, CMS will likely issue a final rule that will go into effect in 2021.”

There's no way to know how CMS will respond, but ACP is optimistic. “There is a lot of agreement among the medical societies about many of the issues that ACP has highlighted, so we are hopeful that CMS will act on some of them,” Outland said. “Should CMS not act on high-priority areas, there are other avenues to address these issues such as through the CPT Editorial Panel, Congress and additional advocacy.”

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