The ACC joined fellow stakeholders in submitting coalition letters to both the U.S. Congress and the Centers for Medicare and Medicaid Services (CMS) voicing concerns with evaluation and management (E/M) coding and payment proposals included in the 2019 Physician Fee Schedule (PFS) proposed rule. The submission of these letters is the latest in a series of efforts the College has undertaken to address comprehensive, and potentially disruptive, payment policy changes included within the proposed rule.

The letters commend CMS for engaging in the serious discussion on simplifying documentation to allow clinicians to focus on quality of care instead of burdensome administrative requirements. However, the coalition urges that additional modeling is necessary to accurately estimate the impacts of these changes before moving forward with implementation. The coalition believes CMS can and should finalize sensible documentation reforms, while retaining the existing five-level coding structure as expert stakeholders work with the agency to create a consensus coding and payment structure that substantially improves on the current system.

The ACC joined the American Medical Association and others in submitting a similar sign-on letter earlier in the month, in addition to providing CMS with independent comments on how proposed changes to payments for E/M services, the Quality Payment Program, appropriate use criteria program for advanced imaging, and other key areas, could impact the practices of cardiovascular professionals. The College is thoroughly analyzing the implications of and solutions to these proposed changes and will provide further breakdown in the coming weeks.

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

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