Groups that represent doctors across the country have submitted detailed comments on the proposed Medicare physician fee schedule for 2018, which the federal government released in July.
As they parsed the details of the fee schedule, they urged the Centers for Medicare & Medicaid Services to continue its promise to reduce the regulatory burden on clinicians.
One proposed change—to reduce payments to some hospital-owned, off-campus practices to further level the playing field for independent practices—drew criticism from a top hospital group.
The American Hospital Association expressed its serious concerns with the proposal, which would reduce the payment for “nonexcepted” services provided in off-campus provider-based departments. Making such an adjustment in 2018 "would be arbitrary and capricious, unreasonable and unsupported by existing data, and in violation of the Administrative Procedure Act,” AHA Executive Vice President Tom Nickels wrote in a letter (PDF) to CMS.
In a 27-page letter (PDF) of its own, the Medical Group Management Association joined the AHA in expressing concern about the data CMS will use to calculate 2018 payment rates for the clinical lab fee schedule. The MGMA urged CMS to verify the accuracy of the data before applying it to payment, while the AHA said it was concerned the data was “unreliable and incomplete.”
The MGMA supported a proposal aimed at creating a smoother transition to the new Merit-Based Incentive Payment System (MIPS). It would reduce or eliminate financial penalties from earlier CMS programs that would otherwise hit some doctors in 2018.
The American College of Rheumatology supported numerous changes to the payment schedule, including practice reporting requirements, value modifier program adjustments, relative value units and appropriate use criteria, which it said would achieve greater program flexibility and simplification for providers.
But it also asked for modifications to the rule, such as a proposed reimbursement cut for musculoskeletal ultrasound services and revisions to Medicare’s evaluation and management codes. Both the AHA and MGMA supported a plan to delay appropriate use criteria requirements.