Monday was the deadline for CMS to receive comments regarding proposed changes to its 2019 physician fee schedule for Medicare, and 14,644 comments poured into the agency, with many physician organizations and individuals asking the agency to halt or slow down its plans to cut physician reimbursement for evaluation and management (E/M) services.
While some groups cheered some of the changes—such as broader coverage for telehealth and other digital monitoring—most expressed concerns with the changes, which would also include a reduction in Medicare reimbursement for new drugs from wholesale acquisition cost (WAC), and issues with the Merit-based Incentive Performance System (MIPS).
Medical and specialty organizations like the American Medical Association (AMA), American College of Rheumatology (ACR), the American Society of Clinical Oncology (ASCO), and the American College of Physicians (ACP) have criticized the move to create a flat payment for all E/M visits, regardless of the complexity of the patient, by collapsing 4 levels of office visits, along with their with successively higher rates, into 1 flat rate.
CMS has said the change is part of its effort to reduce paperwork burdens on physicians, but organizations said they don’t want their reimbursement tied to the agency’s “Patients Over Paperwork” initiative.
“We believe it does not make sense to equate diagnosing and treating a patient with cancer, rheumatoid arthritis, or ALS to a patient with the common cold,” wrote the ACR in their comments, suggesting that the proposal could also lead practices to avoid the sickest patients in favor of healthier ones.
In a letter sent to CMS last month, the AMA and other groups said they were worried about the “unintended consequences” of some of the proposals, such as the one that would fold payment rates for 8 office visit services for new and established patients to 2 each.
Chemotherapy administration could be affected, for example, the letter said, and the sickest Medicare patients could be affected.
For its part, ASCO said in its comment that CMS’ forecast of a 4% reduction in overall resources for their specialty equates to $76 million in reduced funding for cancer care, which ASCO said could exceed a 10% reduction for some individual oncology practices. Combined with payment adjustments from MIPS, “oncology practices that are already struggling financially will be unable to survive,” ASCO wrote.
ASCO also does not want CMS to move forward with the proposed reduction in the add-on rate for Part B drugs subject to payment through the WAC methodology. The proposal would reduce the add-on percentage for Part B drugs paid according to WAC from 6% to 3%. Part B drugs are usually complex drugs administered in a physician’s office.
ASCO asked instead that CMS focus on solutions that “drive value-based cancer care.” It also encouraged the adoption of the Patient Centered Oncology Payment Model as an advanced alternative payment model (APM). “Additional advanced APMs are needed to promote ongoing patient access to cancer care and foster new value-based approaches to cancer care,” the organization wrote.
If approved, the policy would take effect in January 2019, but the organizations urged CMS to hold off. The AMA said it is already communicating with CMS.
Alternatives have to be tested first, said the ACP.
The ACP said it wants several improvements to MIPS, such as reducing the complexity and administrative burden, increasing program flexibility, and delaying the implemention of the new requirements to use 2015 Certified Electronic Health Record technology by a year, especially since providers will be scored on their use of it, the organization said.