The Centers for Medicare & Medicaid Services (CMS) recently released its proposed changes to the 2019 Physician Fee Schedule (PFS) with a Sept. 10 deadline for public comment. The rule would enact sweeping changes to E/M visits covering both documentation requirements and, more importantly, physician payment.
Effective Jan. 1, 2019, under the proposed rule, CMS would:
- Collapse eight payment rates for office and outpatient Evaluation and Management (E/M) visits down to two rates; and,
- Implement a Multiple Procedure Payment Reduction (MPPR) policy that would cut osteopathic manipulative treatment (OMT) and other procedures by 50 percent when billed with an Evaluation and Management (E/M) visit with modifier 25 appended.
“The AOA is advocating that the proposed E/M documentation changes be decoupled from the payment policy,” said David Pugach, AOA senior vice president of public policy. “We also oppose the MPPR to preserve OMT services, as well as other services, and are concerned about the impact of the proposed MPPR on patient care and access. It is important that DOs make their voices heard and submit their own personal comments on the potential impact of these proposals to CMS.”
Advocacy in action
The AOA is urging CMS not to adopt the 50 percent payment reduction policy and to delay finalizing payment changes for E/M visits until appropriate rates are developed for different level visits, and your help is needed in this endeavor.
CMS needs to hear from osteopathic physicians that these proposed policy changes are flawed and ultimately will jeopardize Medicare beneficiaries’ access to care by disrupting your ability to provide medical services in a timely and cohesive manner.
Please use the template here to send a letter directly to CMS urging a delay in finalizing payment policies for E/M visits. DOs are urged to personalize their comments in order to add impact to their statements.