2020 Physician Fee Schedule Organizational Comments around CME, Open Payments and Evaluation and Management Codes

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Later this week or early next Week CMS will issue the 2020 Physician Fee Schedule.  We have previously written about the proposed 2020 Medicare Physician Fee Schedule and its important proposed rules related to CME, Open Payments, Evaluation and Management codes (E/M), and other reimbursement policies. With the release of the final 2020 Fee Schedule coming soon, we thought it might be worth reviewing what some major organizations had to say in response to CMS’ proposal. Below we look at CME-related comments, E/M code feedback, and a few reimbursement arguments made by physician specialty societies.

Comments Related to CME and Open Payments

CME Coalition

The CME Coalition provided feedback on a number of CME topics, including issues related to the proposed MVP framework under CMS’ Quality Payment Program. CME Coalition writes:

As CMS develops the MVP framework, we stress the importance of considering qualified CME in the final rule and future rulemaking on MVPs. It is currently considered an Improvement Activity under MIPS but could play a larger role in the more cohesive MVP framework envisioned by CMS. Qualified CME is especially important because it can improve beneficiary outcomes, lead to practice improvement, can be performed by providers of all types, is feasible to implement, can be validated by CMS, and is evidence-based. Additionally, many believe legacy CMS programs such as the Physician Quality Reporting System (PQRS), Meaningful Use, and Value Modifier would have achieved significantly greater success had physicians received the education and training on these topics that certified CME provides.

Accreditation Council for Continuing Medical Education

The ACCME’s comments were interesting, especially for its focus on reducing regulatory burdens:

We value and support CMS efforts to simplify the regulatory burden on clinicians and healthcare teams. ACCME believes that the MVP framework is a positive evolution to recognize opportunities to harmonize quality measures and improvement-focused activities (e.g. MIPS Improvement Activities, QCDRs) around areas of practice-specific work by participating clinicians and teams. We also recognize that a number of accredited CME providers are already harmonizing quality measure reporting, QCDR participation, and MIPS Improvement Activities as features of current accredited CME offerings that support performance improvement for clinicians. These existing approaches by accredited CME providers exemplify the recent Foundational Recommendations of the American Board of Medical Specialties (ABMS) Vision Commission that, “professionalism, assessment, lifelong learning and advancing practice must be part of continuing certification programs. The elements should not be siloed in a four-part framework, but rather should be multi-sourced and based on the cognitive and technical skills and competencies required for optimal care in each specialty.” We encourage CMS to work collaboratively with ACCME and other stakeholders to continue to simplify clinician engagement in quality improvement by more flexibly recognizing continuous improvement work through accredited CME.

Association of American Medical Colleges

The AAMC calls upon CMS to engage closer with stakeholders of the CME community:

The AAMC urges CMS to engage with stakeholders as new categories of covered recipients and payment categories are implemented to increase the accuracy of payment records in the system and facilitate care provider engagement. The AAMC strongly urges CMS to take active steps to decrease the burden for physicians in accessing and addressing payment records during the review and dispute period.

Furthermore:

Decreasing Burden – Registration and 45 Day Review and Dispute Period The AAMC strongly encourages CMS to continue to identify and implement ways to improve the Open Payments system through decreasing the burden associated with two step registration process that many physicians see as a barrier preventing engagement during the brief review and dispute process. We appreciate the system enhancements CMS has made in direct response to public feedback and recommend continued engagement with key stakeholders to address the specific concerns that may arise from the broadened scope of individuals now covered under the Open Payments program. We also suggest CMS consult with stakeholders on potential system or registration enhancements before they are publicly released to ensure those updates are beneficial and user friendly.

Comments on Patient Evaluation and Management (E/M) Codes

American College of Physicians

Like many groups, ACP was supportive of the proposed E/M changes:

ACP applauds CMS for their updated E/M payment proposals and recommends the Agency finalize acceptance of the E/M codes, Current Procedural Terminology (CPT) guidelines, and Specialty Society Relative Value Scale Update Committee (RUC) recommended values exactly as implemented by the CPT Editorial Panel and submitted by the RUC. ACP fully supports CMS’ proposal to align the previously finalized E/M office visit coding changes with the framework adopted by the CPT Editorial Panel.

Despite its support, ACP is calling for further guidance from CMS:

ACP recommends CMS provide additional clarity on what will be accepted for timebased and MDM-based documentation, either in the final rule or through subregulatory guidance. Further, CMS should work to ensure that the auditing guidelines and procedures are updated and aligned to focus on both time-based and MDM-based notes, as well as applied consistently by all auditing organizations.

American Hospital Association

The AHA also shows its strong support for the proposal which was developed by the AMA:

[W]e strongly support CMS’s proposed reversal of its prior methodology and adoption of an alternative framework developed by the Joint AMA CPT Workgroup on E/M. Under this alternative, CMS would assign separate payment rates to all E/M visit levels for new and established patients. However, as CMS develops the specific valuations and payments for the E/M visit codes and any other add-on codes it finalizes, as well as the budget neutrality impact of these changes on other areas of the PFS, we urge the agency to consider the degree of redistribution among specialties that this proposal could create. We further urge CMS to ensure that providers caring for the sickest and most vulnerable patients are not unfairly penalized.

Medicare Payment Issues

American Academy of Neurology

As always in the Fee Schedule, groups raised concerns with CMS payment cuts. In a lengthy tour de force regulatory comment letter, the AAN focuses its attention on cuts to long-term EEG services:

Although the AAN appreciates that the Centers for Medicare & Medicaid Services (CMS) accepted the RUC recommendations for codes 95X18, 95X19, 95X20, 95X21, 95X22, and 95X23, we are greatly disappointed CMS did not accept the RUC recommendations for professional component codes 95X14, 95X15, 95X16, and 95X17 and urge CMS to accept the RUC recommended wRVUs for these codes in the final rule.  

American College of Cardiology

The ACC, as well, expresses its concern over reimbursement for services:

Under the proposed rule, reimbursement for myocardial PET multiple perfusion services would be reduced by roughly 72 percent next year. Other services in the family also face cuts of alarming scale. The ACC is concerned that reductions of this scale threaten the viability of the service in the physician office setting, will limit patient access to this important imaging modality, particularly in rural and underserved areas, lead to poorer outcomes for patients, and increase beneficiary and health care system costs.

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