On Dec. 31, the ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) addressing the following key issues within the 2019 Physician Fee Schedule (PFS) final rule.

1. Evaluation and Management (E/M) Payment Policy: The ACC thanks CMS for recognizing the College's previous recommendations and forgoing the implementation of a multiple procedure payment reduction policy for services provided on the same day as an E/M visit and a single, average payment for E/M levels 2 – 5 in 2019. The College urges CMS to adopt workable alternatives developed by the ACC and fellow stakeholders, including the American Medical Association's Joint Current Procedural Terminology/Relative Value Scale Update Committee CPT/RUC workgroup, or further refine its own proposals in future rulemaking before a revised proposal would take effect in 2021.

2. Direct Practice Expense Inputs: The ACC urges CMS to continue accepting new information from stakeholders during this comment period and beyond, updating inputs for supply and equipment costs as appropriate in future rulemaking.

3. Misvalued Services: The ACC urges CMS to closely follow its defined public nomination process in the future and carefully consider the imbalances it may create if private insurance companies use the process as a tool to reduce provider payment rates.

ACC staff will continue to communicate developments of interest related to the final ruling to ACC members. These adjustments will also be thoroughly discussed during ACC's Cardiovascular Summit, taking place Feb. 14 – 16 in Orlando, FL.

Clinical Topics: Cardiovascular Care Team

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., American Medical Association, Fee Schedules, Medicare, Medicaid, Health Expenditures

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