ACR cautions policymakers that reducing E/M services can compromise patient access to care

In comments submitted to the Centers for Medicare and Medicaid Services (CMS) regarding the 2019 Medicare Physician Fee Schedule proposed rule, the American College of Rheumatology (ACR) cautioned policymakers against implementing a proposal to reduce physician reimbursement for evaluation and management (E/M) services, arguing that doing so could severely compromise patient access to care and further exacerbate the growing rheumatology workforce shortage.

"While we applaud CMS for taking steps to reduce provider documentation and reporting burdens, we have serious concerns about the impact these cuts will have on patient access to rheumatology care," said David Daikh, MD, PhD, President of the ACR. "A one-size-fits-all approach to reimbursement is not the way to move forward, and cuts of this magnitude will not only force physicians to spend less time with patients but could also dissuade medical students from pursuing careers in rheumatology and other specialties that treat a high volume of patients with complex needs."

CMS' proposal, which would create a flat payment for all E/M visits regardless of complexity, would result in significant payment cuts for treating patients with complex care needs – penalizing doctors who treat sicker patients or patients with multiple chronic conditions. These cuts also go against the recommendations of the Medicare Payment Advisory Commission (MedPAC), which earlier this year found that E/M services are undervalued relative to other physician services and recommended that reimbursements be increased rather than cut. The ACR recommends that CMS implement only the documentation relief elements of the E/M proposal, while delaying the payment changes so CMS can work closely with physicians and all stakeholders to identify alternative approaches that would ensure physicians are appropriately reimbursed according to the level of care required by each individual patient's condition.

The ACR also expressed concern that CMS' proposal to reduce reimbursements for procedures performed on the same day and billed as a separately identifiable E/M visit could reduce quality of care and lead to higher co-pays for patients by requiring them to return on a different day for minor procedures.

Additionally, the ACR urged CMS to:

• Maintain the Merit-Based Incentive Payment System (MIPS) small practice bonus at 5 percent of the final score rather than move it to the quality performance category as is currently proposed.
• Not move forward with a proposal to increase the weight of the cost performance category to 15 percent in the 2021 MIPS payment year. The ACR also urged CMS to use the best 90 days in the Cost category when calculating MIPS payment bonuses rather than the entire calendar year and exclude Part B medication costs from the cost performance category.
• Provide physicians with more credit for participating in specialty clinical data registries under MIPS, such as the ACR RISE Registry which uses electronic health records to improve patient care, outcomes, and practice efficiency.
• Rely on input from all stakeholders about inappropriate and excessive reduction in practice expense reimbursement for diagnostic ultrasound and other services.

"The ACR remains dedicated to ensuring that rheumatologists and rheumatology health professionals have the resources they need to provide patients with high quality care and will continue to advocate for payment reforms that reflect the way practices treat patients," Dr. Daikh said. "We look forward to serving as a resource for CMS as it develops and implements its final 2019 Physician Fee Schedule rule."