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Society calls for changes to proposed Medicare Physician Fee Schedule and Quality Payment Program rule

The Wisconsin Medical Society weighed in on proposed changes to the Physician Fee Schedule (PFS) and Quality Payment Program (QPP) in a 10-page comment letter submitted this week to the Centers for Medicare and Medicaid.

In addition to updates to both the PFS and QPP, this year’s 665-page proposed rule also includes a request for information (RFI) regarding price transparency and a new series of bundled payments and reporting measures to address the opioid crisis.

PFS updates include expanded payment for telemedicine procedures, changes to supervision requirements for radiologist assistants, and reimbursement changes for federally qualified health centers and rural health centers—all which the Society supports. The Society expressed opposition to proposed changes to reimbursement for Part B Drug add-ons and suggested ways for CMS to better construct wage data for physicians as it relates the geographic price cost indicator (GPCI).

The biggest change to the PFS, however, involves documentation and reimbursement for Evaluation and Management (E/M) codes. CMS has proposed reducing documentation requirements for E/M codes by allowing physicians to use 1995 or 1997 guidelines, medical decision making or time to document the appropriate level of an E/M patient visit. And while this undoubtedly would reduce administrative burden for physicians, any positive impact likely would be offset by proposed changes to reimbursement.

Currently, physicians can bill Medicare at one of five levels depending on the intensity and duration of the patient visit. The proposed rule would decrease those levels to two. CMS asserts that the reduced documentation requirements would offset the need for higher reimbursement levels, but by its own estimates, acknowledges this change would create winners and losers depending upon a physician’s specialty.

In its letter to CMS, the Society supported the reduction in documentation requirements but opposed restructuring reimbursement levels.

“At a time when CMS is emphasizing quality over quantity in health care, it would be counterproductive to remove the ability for physicians to appropriately bill for the time to provide quality care. Treating difficult and complex patients simply requires more time. Adequate reimbursement for time spent with patients should be rewarded,” wrote Society CEO Bud Chumbley, MD, MBA, in the comment letter. “We do not think that reductions in unnecessary administrative documentation should come at the expense of physician reimbursement without further study by CMS or relevant federal agencies.”

Quality Payment Program
Proposed changes to the QPP include creating an opt-in option for physicians who don’t automatically qualify for participation in the Merit and Incentive-based Payment System (MIPS), a change the Society supports. CMS also proposes updating scoring weights for the MIPS performance categories, increasing the Cost weight from 10 percent to 15 percent and reducing the Quality component from 50 percent to 45 percent. The Society called on CMS to identify proposed changes to scoring weights for the MIPS program for the next five years, so physicians can plan for new reporting requirements and structures.

The proposed rule does not include many changes for Advanced Alternative Payment Models (APMs) except extending the revenue-based risk standard and requiring that 75 percent of APM clinicians must use a certified electronic health record. The Society requested that CMS maintain these thresholds for at least the next three years to allow adequate incorporation into practice.

Price Transparency
Citing the Society’s existing policy on price transparency, Dr Chumbley said the Society would like to see CMS put forth incentives and regulations that would have both hospitals and insurers disclose to patients the true costs of care, as well as publicly posted Medicare and Medicaid payments for services, drugs, procedures and treatments. Any price transparency effort should help facilitate physician-patient discussions when making medical decisions. Further, he suggested that CMS require both outcome and price transparency disclosures for hospitals and health systems.

Opioid Measures
Regarding proposed bundled payments for substance use disorder services and MIPS measures relating to querying prescription drug monitoring databases and verifying opioid treatment agreements, Dr Chumbley said, “The Society strongly supports CMS’s focus and prioritization of policies aimed at addressing the opioid crisis,” and urged that these new payments and measures must take into account the impact they would have on physician workflows, while also promoting patient safety and access to care.

Click here to read the Society’s comment letter. The proposed rule is available here. If you have any questions, contact H.J. Waukau.

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