Reimbursement News

Docs Laud E/M Proposal, Blast Pay Cuts in Physician Fee Schedule Rule

The proposed rule for the Physician Fee Schedule drew thousands of comments, including praise for separate E/M rates and criticism for reimbursement cuts and a new MIPS reporting system.

Medicare Physician Fee Schedule

Source: Thinkstock

By Jacqueline LaPointe

- As the comment period for the proposed 2020 Medicare Physician Fee Schedule rule drew to a close on Friday night, CMS received over 30,000 comments, including letters from major industry groups commending the agency for proposing to do away with a policy that would collapse evaluation and management (E/M) payment rates.

CMS decided in the 2019 Medicare Physician Fee Schedule final rule to consolidate E/M levels 2 through 5 into a single payment rate by 2021 to reduce the administrative burden associated with Medicare documentation requirements.

Facing staunch industry criticism, the federal agency proposed earlier this year to walk back on the policy, which many industry groups are now praising.

“CMS recognized that its earlier plan for E/M visits would have disrupted care patterns and may have created other unintended consequences. Having the separate codes helps acknowledge the difference in resources in treating patients with more complex care needs,” the American Medical Group Association’s (AMGA) president and CEO Jerry Penso, MD, MBA, said in a statement.

Finalizing the proposal to keep separate E/M payment rates would also avert unintended consequences, such as forcing “medical practices to reduce their Medicare patient volume or limit the medical issues addressed during one office visit due to lower reimbursement rates for more complex visits,” MGMA stated in its comments.

READ MORE: Does the Medicare Physician Fee Schedule Undervalue Primary Care?

However, hundreds of commenters said wins for physicians should not come at the expense of other providers, including clinical social workers.

In response to the proposed four percent payment cut in 2020 to clinical social workers, one commenter said the “nation can ill afford to implement disincentives to CSW participation in Medicare, given the skyrocketing growth of the Medicare population, many of whom live with anxiety, depression and other challenges that CSWs are uniquely qualified to address.”

In a similar vein, many commenters opposed potential payment reductions for other providers, including psychologists and physical therapists.

A clinical psychologist and Medicare provider for 20 years, for example, warned CMS that the proposed seven percent reimbursement cut to psychologists will encourage more of the providers to “opt out of the plan and many more Americans will lose access to the health and behavioral, psychotherapy, testing and supportive services that they desperately need.”

The proposed eight percent cut for physical therapy services could also exacerbate the shortage of physical therapy and physical therapy professionals, which is already estimated to be 27,000 physical therapists by 2025, another commenter stated.

READ MORE: The Difference Between Medicare and Medicaid Reimbursement

Stakeholders also criticized CMS’ proposal to reform the reporting system for the Merit-Based Incentive Payment System (MIPS), a program that adjusts Medicare Part B reimbursement based on clinician performance on certain measures.

As part of MACRA’s Quality Payment Program, MIPS aims to accelerate the transition to value-based care and reimbursement by tying clinician payments to quality and cost performance. But clinicians have complained that the program that launched in 2017 is too complex and burdensome.

CMS proposed in the 2020 Medicare Physician Fee Schedule rule to revamp the reporting system for MIPS. The agency proposed to create the MIPS Value Pathways (MVPs), a conceptual participation framework that would streamline MIPS reporting by requiring eligible clinicians to report on a smaller set of measures that are specialty-specific, outcome-based, and more closely aligned with alternative payment models starting in the 2021 performance year.

Some industry groups, however, thought the MIPS reporting system proposal does not go far enough to address some of the most fundamental issues providers have with the value-based reimbursement program.

“Most notably, the framework fails to truly deconstruct the silos that currently separate each performance category. Instead, it simply attempts to connect the performance categories under a common theme but maintains a structure where each category still has a distinct set of measures/activities and a unique set of reporting and scoring rules,” the Alliance of Specialty Medicine commented.

READ MORE: OIG Suggests Lowering Medicare Reimbursement for More Part B Drugs

CMS also needs to develop the capabilities to allow for effective and successful MIPS Value Pathways participation before implementing the new reporting system, many stakeholders agreed. One of those capabilities is prospective beneficiary attribution.

“Current beneficiary assignment under MIPS is retrospective, which providers find disadvantageous to their ability to plan and create care processes,” AMGA stated in its comment letter. “Under a retrospective arrangement, providers are not able to target coordination strategies to beneficiaries in the model.”

“Under an MVP construct centered on a specific disease or condition, prospective assignment would allow providers to know which beneficiaries will be included in their cost and quality measurements. This creates a foundation on which providers can build a care delivery model,” the association added.

CMS will now consider the tens of thousands of comments before finalizing the 2020 Medicare Physician Fee Schedule rule. Stakeholders will have to wait and see whether CMS heard their voice when finalizing policies that will impact their Medicare B reimbursements next year.