IMS Weighs in on CY20 Medicare PFS and Quality Draft Rule

Last Friday marked the close of the public comment period for the CY20 Medicare Physician Fee Schedule (PFS) and Quality Program draft rule. This annual update to the rules impacting physician participation in the Medicare program has grown exponentially longer in recent years as the Centers for Medicare & Medicaid Services (CMS) has rolled out additional components of the Quality Payment Program (QPP) and request for information as they build new elements of the practice transformation effort. The IMS written comments focused on a number of familiar areas, as well as new quality program changes under consideration. These include:

· Ensuring Geographic Payment Equity

Federal statute requires that every three years CMS update the Geographic Practice Cost Index (GPCI) payment adjustments, which disproportionately target rural states for payment reductions. IMS voiced continued support for addressing the underlying problems with the GPCI formulas and urged action to prevent the loss of the 1.0 Physician Wage GPCI floor that is set to expire at the end of 2019. Loos of this floor, along with the GPCI adjustments proposed in the rule, would result in an estimated $22.5 million Medicare rate cute for Iowa physicians.

· Payment for E/M Services

The proposed CY20 rule seeks to avoid the majority of the drastic E/M coding and payment changes put forward in last year’s rule. Under the leadership of an AMA-convened workgroup, alternatives to this proposal were developed – the majority of which are incorporated in the draft rule. IMS urged CMS to implement the changes developed by the workgroup and join the medical community in pushing Congress to implement corresponding positive updates to the Medicare conversion factor to avoid a substantial redistribution in payments to offset the necessary payment increases included in the draft rule

· Expanding Telehealth Services

IMS voiced support for the additional flexibility in geographic and originating site restrictions for select telehealth services that are included in the draft rule. We reminded CMS of the vast, underutilized potential of this technology to help ensure access to care for rural seniors and urged more broad-based demonstration projects to lift all Medicare restrictions on utilizing telehealth to provide additional services.

· Substance Use Disorder Treatment

The proposed rule includes the expansion of these bundled payments largely in line with the joint recommendations of the AMA and the American Society of Addiction Medicine, which represent positive progress in the fight to increase access to SUD treatment. IMS reminded CMS that opioids are still only the fourth-most misused substance in Iowa and urged broad interpretation of its statutory authority to allow for programs and resources that assist states to increase SUD treatment across the board.

·  Supervision of Physician Assistants

IMS urged caution over the provisions of the draft rule, which seek to roll back requirements for supervision of physician assistants when the current process is working well. We also reminded CMS of the recent multi-year state-level policy fight that resulted from the last CMS attempt to alter supervision requirements for remote practice physician assistants.

·  MIPS Value Pathways

The draft rule included an extensive request for information and proposed framework around a new Merit-based Incentive Payment System (MIPS) Value Pathways (MVP) model as a means of moving more physicians from the MIPS track toward the Alternative Payment Model of the QPP program. Such a model holds the promise of reduced administrative burden and confusion for small, independent practices if constructed appropriately and on a realistic timeframe. IMS urged CMS to utilize a deliberate, inclusive process as it designed the elements of this new model.

·  MIPS Quality Performance Categories

IMS voiced strong concern over the proposed restructuring to category scoring, which is not in alignment with efforts such as the Patients Over Paperwork initiative and largely represent an unachievable ideal in current iterations. We also urged CMS to reassess the MIPS participation and projected incentive payments and its marketed ceilings in light of ongoing concerns that true payment adjustments for even the high-scoring Iowa practices rarely if ever align with CMS-outlined incentive levels.

The full IMS written comments are available here. The AMA also submitted extensive written comments on the draft rule, which are available here. For more information on this issue, please contact Dennis Tibben with the IMS Center for Physician Advocacy.

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