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MSMS Comments on Medicare Payment Proposals
MSMS made its views known to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed 2019 Medicare physician fee schedule and quality payment program (QPP) rule in two letters to CMS Administrator Seema Verma.
Joining the AMA and 168 other organizations, MSMS signed on to a joint letter to CMS opposing CMS' proposals to collapse payment rates for eight E/M office visit services into two.
We oppose the implementation of this proposal because it could hurt physicians and other health care professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients' access to care," the letter states.
The joint letter also indicated support for CMS' "Patients Over Paperwork" initiative and urging three of its components to be enacted immediately to reduce "note bloat" redundancy. Specifically, MSMS and the other organizations called for immediate adoption of the following proposals:
Changing required documentation of patient’s history to focus only on the interval since the previous visit.
Eliminating requirement for physicians to redocument information that has already been documented in the patient’s record by practice staff or by the patient.
Removing need to justify providing a home visit instead of an office visit.
In a separate letter, MSMS further stressed its opposition to the proposed E/M changes and support for the recommendations in the health care stakeholder's joint letter including the suggestion to allow the AMA's workgroup to further analyze the issue and develop actionable recommendations for submission to CMS for consideration. Additionally, MSMS noted its opposition to proposals to reduce payments for multiple services delivered in the same day and mandatory use of 2015 Edition of Certified Electronic Health Record Technology under the Merit-Based Incentive Payment System (MIPS).
Finally, MSMS acknowledged proposals worthy of support such as removing the prohibition on same-day E/M visits billed by physicians in the same group or medical specialty and adding the number of covered professional services as a third contributing element to the MIPS low-volume threshold determination.