AMA Offers Comments to CMS on its 2019 Medicare Reform Proposal

Sep 11, 2018 at 04:31 pm by Staff


The American Medical Association (AMA) submitted comprehensive comments today to the Centers for Medicare & Medicaid Services (CMS) that outlined recommended changes to the proposed rule on physician payment policies.

In its comments, the AMA compliments CMS for some of the changes - most notably, the regulations that target excessive paperwork - as well as policy changes in digital medicine and alternative payment models.

The AMA's comments also elaborate on concerns that the AMA and 170 other medical organizations expressed recently about changes to Evaluation and Management (E/M) services. If the proposed rule were adopted, the sickest patients - and the physicians who treat them - would encounter significant obstacles to care.

"This provision in the proposed rule should be filed under the category of unintended consequence - or good intentions that go awry," said Dr. Barbara L. McAneny, MD, president of the AMA. "While CMS started out with the laudable goal of reducing paperwork and allowing physicians to spend more time with their patients, the cascading impact of such regulations would be bad for patients and physicians."

The AMA believes that CMS has proposed several important improvements, and the nation's largest physician organization welcomes the agency's emphasis on simplification. The effort to streamline documentation requirements will reduce note bloat, improve workflow, and contribute to a better environment for health care professionals and their Medicare patients.

Regarding the proposal to collapse payment rates for eight office visit services for new and established patients down to a total of two, that is where the unanswered questions linger. As written, they would hurt physicians who treat the sickest patients as well as those who provide comprehensive primary care, ultimately jeopardizing patients' access to care. The AMA does not think that the authors of this rule intended to limit coverage for patients who require complex services, but that would be the result. The AMA letter urges CMS to set aside this part of the proposal.

The AMA has convened a working group comprised of a broad spectrum of health professionals to come up with a better alternative that could be implemented in 2020. It is already meeting and communicating with CMS.

"The agency has been a willing listener, and we think there is opportunity to make this rule a plus for patients and physicians. This is complex work. Big picture proposals must work within the everyday demands facing working physicians," McAneny said.

Other comments within the 136-page response include:

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