IMS Weighs in on Medicare Fee Schedule Rule

Date of Publication: August 29, 2018

This week, IMS submitted written comments on the proposed revisions to payment policies under the Medicare Part B Physician Fee Schedule (PFS) for CY 2019. This year’s annual draft rules, which will be finalized in November, include some of the most extensive changes to Medicare physician payment structure in a number of years. Among these are several proposals aimed at eliminating redundant documentation requirements and reducing the administrative burden on physician practices. While IMS and the medical community applaud many of these proposals, some come with potentially significant negative consequences for some medical specialties.

This includes the much-discussed proposal aimed to reduce reporting and documentation requirements by collapsing the current E/M codes and corresponding payment levels from eight office visit services to two. Both CMS and the AMA have completed an analysis of the results of such actions. These reviews show that while some physician specialties and non-physician providers will see a rate increase under the proposed new E/M structure, that increase would come at the expense of other physician specialties that would sustain substantial reductions in Medicare payment.

In response to this proposal, the AMA has convened a special workgroup of physicians and other policy experts to examine the E/M proposal and resulting issues, with the goal of providing recommendations to CMS for an equitable, concrete solution to this potential problem. Initial meetings of this group with CMS representatives have shown promise that the agency is open to revisiting the proposal.  In its written comments, IMS voiced support for this work and emphasized the importance of our mutual goal to reduce administrative burden, while not disproportionately harming badly-needed specialties or dividing the medical community against itself.

The AMA also submitted written comments this week on the proposed E/M changes. IMS joining numerous state and national physician organizations in signing on in support of the letter, which again emphasized the importance of this workgroup and collaborating to find an equitable solution to this potential problem.


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