AMA seeks comments on CMS proposed rule on fees, QPP
The AMA is asking national specialty and state medical societies to give input on the proposed physician fee schedule (PFS) and Quality Payment Program (QPP) rule for 2019, which the Centers for Medicare & Medicaid Services (CMS) recently released. 

In a conference call with federation members July 27, Richard Deem, AMA’s senior vice president for advocacy, emphasized that some changes will reduce burdensome documentation requirements. At the same time, he said, others could have unintended consequences for doctors and patients. For example, CMS proposes to pay a single amount for Level 2 through Level 5 evaluation and management (E/M) services for office/outpatient visits, reducing payments for some specialists and possibly disincentivizing the treatment of complex cases. CMS is also proposing add-on codes, which would add $5 to each office visit performed for primary care purposes and $14 to office visits performed by certain specialties.  

The AMA’s initial summary of the proposed 2019 rule is online. The deadline to provide comments to CMS about the proposed rule is Sept. 10. Submit comments >>

The AMA prepared the analysis of the proposed rule below. The rule is expected to be released in early November. 

AMA analysis of proposed 2019 PFS/QPP rule

Positive elements
  • A major reduction of the documentation burden for evaluation and management (E/M) office visit codes.
  • New payments for physician services that are not part of a face-to face-office visit, such as virtual check-ins, remote consults of patient videos, and photographs and online consultations with other physicians.
  • Continuation and expansion of a low-volume threshold exception policy exempting small practices from the Merit Incentive Payment System (MIPS).
  • A reduction in problematic measures in the promoting interoperability provisions, formerly the meaningful use and advancing care information.

AMA-recommended changes
  • Further reductions in quality-measure requirements, to reflect reductions in available quality measures.
  • Simplifying the MIPS scoring framework to make it more clinically relevant and understandable for physicians.
  • Testing and adoption of physician-focused alternate payment models (APMs).

Concerns regarding the impact of proposed E/M coding changes
CMS is seeking to reduce the administrative burden on physicians by collapsing codes and payment levels for E/M services. An AMA table, “Estimated Impact of CY2019 Evaluation and Management Proposed Policy by Medicare Specialty,” shows the specific impact of these changes on payments for separately reported office visits. 

(The AMA table is available online.) This is the key difference between the percentage impacts shown in Table 22, included in the CMS proposed rule, where the monetary redistribution of the E/M proposal was displayed as changes in total Medicare allowed charges by specialty. (CMS’ Table 22 is available online

The AMA table summarizes the specific E/M impact for each Medicare designated specialty with more than $1 million in office visit spending, while the CMS table displays impacts with less specialty granularity. (For example, hematology, medical oncology and hematology/oncology are collapsed into hematology/oncology in Medicare impact tables, while the AMA table shows the impacts on each individual specialty.) 

Like CMS’ Table 22, the AMA analysis does not include the proposed new add-on code GPRO1 for prolonged evaluation and management or psychotherapy service or services (beyond the typical service time of the primary procedure) in the office or other outpatient setting, requiring direct patient contact beyond the usual service of 30 minutes. The criteria for reporting the service has not yet been determined, and data on current time spent in direct contact beyond the usual service is not available.

What’s next
The AMA appreciates CMS’ genuine desire to reduce documentation burdens on physicians to allow them to focus on patients over paperwork. The AMA applauds the effort to reduce administrative burdens, as it promises to improve both patient and physician experiences with care. 

The AMA has heard concerns from some specialty societies regarding the payment policy changes. It has been in touch with CMS, which has indicated its willingness to work with physicians on possible modifications. The AMA is focused on offering constructive recommendations to reduce administrative burdens and establish payment policies that enable physicians to deliver high-quality care for seniors. The AMA will continue to provide updates.

Read CMS's proposed 2019 rule >>

CMS QPP Fact Sheet >>
PFS Fact Sheet >>