Health and Human Services Director Tom Price. Credit: Twitter
AMA supports many of the federal proposals for the revised Medicare physician fee schedule but also wants to see greater flexibility to reduce the burden of the quality payment program.
CMS in July issued a proposed rule that includes an update of payment policies, rates, and quality provisions in the Medicare physician fee schedule for January 1, 2018. CMS accepted comment through September 11.
A top concern, according to a Sept. 11 letter to CMS Administrator Seema Verma from AMA CEO James Madara, MD, is CMS's proposal to set payment for services at provider-based off-campus hospital outpatient departments at 25 percent of the hospital outpatient prospective payment system payment rate.
And Madara said he had significant concerns with proposals to report 2016 physician quality reporting system data on Physician Compare.
The AMA dashboard includes the "wins" and "asks" for MACRA's merit-based incentive payment system and advanced alternative payment model payments, and on electronic health records.
On MIPS, the AMA asks CMS to set the composite score performance threshold at six rather than 15 for payment measures.
The AMA does not want Part B drugs included in MIPS calculations or payment adjustments and it wants CMS to simplify the MIPS scoring methodology.
Among other measures, it also wants CMS to provide the maximum flexibility for virtual groups.
On APMs, the AMA wants CMS to extend the 8 percent revenue-based nominal risk standard for the foreseeable future.
It also wants an extension of the medical home risk standard to small and rural practices and does not want APMs restricted to medical homes with fewer than 50 clinicians. It wants CMS to include medical home models with specialty practices.
On electronic health records, the AMA requests CMS work with administrators to prevent health IT vendors from blocking information or making it expensive for physicians to share data with other clinicians.
CMS, under Health and Human Services Director Tom Price, an orthopedic surgeon, has proposed relief to the physician administrative burden for the second year of the Medicare quality payment program and the 2018 Medicare physician fee schedule.
The dashboard of "wins" includes coverage of telehealth services, the reduction of penalties under the value modifier program in 2018, the reduction of documentation submission requirements for the Medicare shared savings program and ACOs, and the expansion of the Medicare diabetes prevention program.
The AMA urges CMS to include online and virtual diabetes prevention program in the Medicare diabetes prevention program model.
Other wins include the delay in implementing the requirement that physicians consult appropriate use criteria before ordering advanced diagnostic images and a reduction in penalties for using legacy reporting programs such as meaningful use and the physician quality reporting system.
Physicians also applaud the proposed rule exempting practices with few Medicare beneficiaries from the MIPS program, and postponing a mandate for physicians to upgrade to 2015 edition certified electronic health records. But EHRs must include enhanced interoperability technology and support for apps.
The American College of Rheumatology added its own proposals in comments to CMS over the proposed Medicare physician fee schedule.
It expressed concern over proposed reimbursement cuts for musculoskeletal ultrasound services, revisions to Medicare's evaluation and management codes, and the agency's plan to assign the same billing and payment code to all biosimilar products of a reference biologic.