ACC Comments on Changes to E/M Services, QPP Updates in CMS’ Proposed PFS Rule

On Sept. 6, the ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the 2019 Physician Fee Schedule (PFS) proposed rule. The comments address many important proposals but devote special attention to documentation changes to evaluation and management (E/M) visits and updates to the Quality Payment Program (QPP) among other key areas.

The ACC appreciates the agency's focus on reducing clinicians' documentation burden by proposing changes to documentation standards for E/M services; however, the College urges CMS not to finalize this package of proposals in its entirety for implementation on Jan. 1, 2019. The ACC believes CMS could move forward with several of its proposals to reduce documentation burden without also making dramatic, comprehensive and disruptive payment policy changes. Instead, because of CMS' renewed focus to this topic, the agency should build on this momentum to make changes in concert with stakeholders through town halls, requests for information and, most importantly, through the American Medical Association's Joint Current Procedural Terminology/Relative Value Scale Update Committee (CPT/RUC) Workgroup. The (CPT/RUC) Workgroup and fellow stakeholders are striving to develop innovative, concrete solutions that could be deployed for implementation as soon as the 2020 Medicare Physician Fee Schedule.

ACC comments on Year 3 updates to the QPP address scoring and components of the Merit-Based Incentive Payment System (MIPS), Qualified Clinical Data Registries (QCDRs) and Advanced Alternative Payment Models (Advanced APMs).

The College strongly encourages CMS to provide participation data on Year 1 of the MIPS program as soon as possible so it can be used to inform future refinements to the program. In this proposed rule, CMS continues to rely on data from legacy programs to calculate its historical assumptions. While the goals of the QPP, particularly the MIPS track, are based from these legacy programs, actual QPP data is needed to understand how to best improve the program.

Additionally, the College requests that CMS make an effort within the QPP to balance the need for flexibility with the ability to offer true incentives to those who deliver exceptional quality patient care; provide all clinicians with a selection of clinically meaningful measures relevant to their patient populations treated; prevent administrative burden on clinicians, particularly those who are solo practitioners or in small practices; work with clinicians to determine innovative ways to fulfill QPP requirements in future years; and continue to expand opportunities for participation in Advanced APMs.

ACC comments also address the appropriate use criteria (AUC) program for advanced imaging. The College recommends that CMS explore ways that the goals of the AUC program can be accomplished through existing programs, such as the QPP, to minimize administrative burden. Recognizing that CMS is still required by statute to implement the AUC program, the College provides feedback on the process ordering and furnishing clinicians will use to report AUC consultation and poses considerations for the development of the methodology used to identify outliers after reporting begins in 2020.

The College will provide further breakdown of these comments in the coming weeks. Members can submit individual comments here. CMS will post its decisions in the final rule by Nov. 2. ACC Advocacy staff will continue to communicate developments on this issue as they become available.

Keywords: ACC Advocacy, Relative Value Scales, Current Procedural Terminology, Centers for Medicare and Medicaid Services (U.S.), American Medical Association, Medicare, Medicaid, Fee Schedules, Health Expenditures, Patient Care, Referral and Consultation, Registries


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