This week, ASCRS joined with the Alliance of Specialty Medicine in comments on the 2019 Medicare Physician Fee Schedule proposed rule, which included the Quality Payment Program. Echoing ASCRS’ recommendation in its own comment letter, the Alliance strongly opposes CMS’ proposals related to E/M documentation and payment. We reiterate concerns that the proposal to collapse payments for office visits two through five is not resource-based and will affect the overall relatively of the physician fee schedule. Furthermore, the proposal to reduce by 50% the lesser of two codes when a procedure is performed on the same day as an E/M visit is duplicative of efforts by the Relative Value Update Committee (RUC) to revalue certain codes that are frequently performed in conjunction with an E/M visit and will result in steep cuts to physician reimbursement. We recommend CMS not finalize the proposal and allow the medical community to update E/M codes as necessary.
The Alliance also supported CMS’ proposals related to MIPS to reduce burden and extend the transition period. We appreciate CMS’ overhaul of the Promoting Interoperability category that eliminates the confusing base and performance scores and the measures requiring patient action. We continue to oppose the “all-or-nothing” scoring in the category and recommend CMS offer partial credit. We also encourage CMS to identify additional means of simplifying and streamlining the MIPS program as a whole, such as offering credit in all or multiple categories for some activities or measures and aligning the points available in a category with the final score weight. The final rule is expected to be released in November. We will keep you updated.