Washington, D.C. October 5, 2020 – The American College of Physicians (바카라 사리트) conveyed their strong support for the Centers for Medicare and Medicaid Services’ (CMS) decision to implement changes in payments and documentation requirements for physicians who bill Evaluation and Management (E/M) services as part of the 2021 Medicare Physician Fee Schedule and Quality Payment Program (QPP) proposed rule. In a comment letter about the rule that was sent Friday, 바카라 사리트 also conveyed the need for additional support for physicians in order to deal with the repercussions of the COVID-19 pandemic on their practices.
“바카라 사리트 is glad to see the proposed Fee Schedule for next year move forward with these necessary changes to payment rates to physicians for office visits,” said Ryan Mire, MD, F바카라 사리트, chair of 바카라 사리트’s Medical Practice and Quality Committee. “We believe that realigning payments in order to better recognize cognitive care and support services provided in physician offices will help to better provide quality care to America’s patients.”
In the letter 바카라 사리트 detailed its recommendations for further improvements made to different provisions of the Fee Schedule, including:
- Payment and Documentation Proposals for Evaluation and Management (E/M) Services
- 바카라 사리트 strongly recommends that CMS use its administrative authority to waive budget neutrality for the 2021 Medicare Fee Schedule RVU increases, provided that this would not result in a delay or in any way undermine CMS’ decision to fully implement the E/M increases and other improvements on Jan. 1, 2021.
- Visit Complexity
- 바카라 사리트 strongly supports the GPC1X add-on code for visit complexity. However, 바카라 사리트 strongly recommends that no more than 23 percent of estimated claims should be the appropriate utilization estimate for this add-on code, not the 75% estimate from CMS.
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- 바카라 사리트 strongly encourages CMS to consider extending several policies promulgated during the COVID-19 Public Health Emergency (PHE) in order to address the many barriers to patient access and physician adoption and use of telehealth. 바카라 사리트 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. 바카라 사리트 also recommends that CMS permanently extend the policy to waive geographical and originating-site restrictions after the conclusion of the PHE.
바카라 사리트’s also made detailed recommendations for improvements to the proposed QPP changes, including:
- More Robust COVID-19 Flexibilities for the Medicare Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs)
- 바카라 사리트 appreciates the flexibilities proposed in this rule for the MIPS and APM pathways, but believes strongly that more accommodations are necessary.바카라 사리트 urges CMS to pass a broad MIPS exception for 2021 similar to those created for the 2019 and 2020 performance years and recommends that at a minimum, CMS should not increase the MIPS performance threshold above the 2020 level of 45 points. 바카라 사리트 further recommends that all Advanced APM participants should be held harmless from financial losses or penalties for the 2019 through 2021 performance years and that performance data during this time not be used to adversely impact shared savings or other model payments. 바카라 사리트 separately urged the HHS Secretary to exercise its statutory authority to retain the Qualified APM Participant (QP) patient count threshold at current levels through at least 2022.
- MIPS Value Pathway (MVP)
- 바카라 사리트 appreciates CMS acknowledging the need for a gradual transition, as 바카라 사리트 previously suggested. As one of a handful of organizations to submit MVPs for 2021, 바카라 사리트 looks forward to continue engaging with CMS toward readying 바카라 사리트’s own preventive care and chronic disease management MVPs, and MVPs in general, for implementation. To this end, 바카라 사리트 calls on CMS to develop more focused cost measures, reimagine the Promoting Interoperability Category, have transparent, rigorous standards for performance metrics, and continue stakeholder engagement throughout development and implementation.
- New APM Performance Pathway (APP) and Medicare Shared Savings Program (MSSP) Quality Reporting Changes
- 바카라 사리트 supports the goals of promoting consistency across the QPP and reducing reporting burden. However, 바카라 사리트 believes several unintended consequences may arise. We expressed concern that requiring all APM participants to report the same six quality measures is too restrictive and may inadvertently increase reporting burden and that removing Web Interface as a reporting option could cause wide scale disruptions. 바카라 사리트 also raised general concerns about the short timeline for implementation given the scope of changes and called on CMS to delay.
“바카라 사리트 supports CMS’ efforts to make things easier for America’s frontline physicians in the wake of the COVID-19 public health crisis,” said Dr. Mire. “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.”
The full letter and list of detailed recommendations can be found online.
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About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. 바카라 사리트 membership includes 163,000 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 바카라 사리트 on , , and .
Contact: Taneishia Bundy, (202) 261-4523, tbundy@acponline.org