There was a lot for physicians to like in a proposed rule issued this week for 2020 Medicare payment rates and changes to the Merit-based Incentive Payment System (MIPS).
Physician groups were happy the government pulled back on once-controversial changes to evaluation and management (E/M) services, but one group said proposed changes to MIPS will not push practices to transition to value-based care.
The American Medical Group Association (AMGA) offered the most stinging criticism of the proposed rule. Under the proposed changes, MIPS will no longer be a pathway to value-based care and will devolve into what it called a regulatory compliance exercise, the organization said.
Instead of the chance to earn up to a 9% adjustment on Medicare Part B payments in 2022, CMS estimates the overall payment adjustment will be 1.4% under the proposed rule, the AGMA said in a statement.
“In light of this significantly reduced adjustment, AMGA is concerned that MIPS is no longer a transition tool to value-based care, but instead represents a regulatory burden that does not support physician group practices and integrated systems of care that are investing in delivery models based on care coordination and improving population health,” the organization said.
“We are entering the fourth year of MIPS, and our members expected to have the opportunity to earn a significant payment adjustment if they performed well,” said Jerry Penso, M.D., AMGA president and CEO. “By proposing an overly cautious approach, CMS is not rewarding those organizations that made the necessary investments in and championed value-based care as envisioned by congressional leaders.”
CMS introduced a new framework for MIPS called MIPS Value Pathways with the goal of making it easier for physicians to participate in the program by reducing quality reporting burdens.
On the other hand, physician organizations praised CMS for backing away from modifications it proposed last year to overhaul E/M codes that would have paid physicians the same amount for an office visit even when caring for the most complex patients. Faced with intense opposition, CMS last fall put the streamlining of E/M payments on hold in order to work with physician groups.
“We are pleased CMS heard the concerns of frontline physicians and meaningfully addressed them in a way that doesn’t impede our physicians’ ability to practice medicine,” said David Pugach, J.D., senior vice president for public policy at the American Osteopathic Association, in an emailed statement.
“Evaluation and management (E/M) visits have been undervalued for many years, which really hurts physicians practicing in primary care. If adopted, this change prevents significant financial harm to physicians who treat Medicare patients and helps ensure they can continue to care for the most vulnerable patients,” he said.
The American Medical Association (AMA), the Community Oncology Alliance (COA) and the American College of Physicians (ACP) all agreed.
In a CMS fact sheet on the proposed changes, the agency said it would align E/M coding changes with those laid out by a panel set up to study the issue.
CMS proposes to retain five levels of coding for established patients, reduce the number of levels to four for office/outpatient visits for new patients and revise the code definitions. It will allow clinicians to choose the E/M visit level based on either medical decision-making or time.
Ted Okon, executive director for the COA which had been outspoken in its opposition, applauded the E/M changes in the new proposed rule.
"Instead of simply collapsing or reducing reimbursement for evaluation and management services as proposed in past years, CMS has realized that the complexity of cancer care is valuable, as is the expertise and time of the community oncologists who treat patients with complex cancers," he said in a statement.
The AMA, which had led the effort to work with CMS to come up with a plan physicians could live with, also praised the proposal.
“Developed in partnership between the AMA and CMS and with broad input from the medical community, the proposal reflects the increasing complexity of these services and the resources required to provide them, and represents a significant step toward reducing administrative and documentation burdens in medicine,” said AMA President Patrice Harris, M.D.
The Medicare evaluation-and-management proposed rule will alleviate physicians’ documentation burden. The AMA stands ready to help the entire health care community implement the simplified approach to E/M documentation and coding. https://t.co/eY0u7eyQBa— AMA (@AmerMedicalAssn) July 30, 2019
“The proposed changes to documenting and coding for office visits will streamline reporting requirements, reduce note bloat, improve workflow, and contribute to a better environment for healthcare professionals and their Medicare patients,” she said. The AMA has created a web page with information about the proposed changes.
Unlike the AMGA, the AMA welcomed what it said is a simplified option for MIPS that gives physicians the choice to focus on episodes of care.
The ACP said it supports changes that put patients at the center of care and support primary care. Among the changes it applauded were increased payments for office/outpatient E/M visits starting in 2021.
“By making changes to shore up payment for primary care services, CMS is ensuring that they are putting patients first and helping them access the care they need,” Robert McLean, M.D., ACP president, said in a statement.