The CMS received a mixed reaction from physician advocacy groups to its proposed Medicare Physician Fee Schedule for 2014. While the physician groups cheered a proposal to have Medicare pay for care-coordination activities conducted outside of traditional face-to-face doctor-patient encounters, it criticized the agency for proposals that would reduce payments for services received in physician offices.
The groups noted that while progress has been made in Congress in finding a replacement to the sustainable growth-rate Medicare payment formula, an SGR-driven 24.4% pay cut scheduled to take effect Jan. 1, 2014, is still a concern.
“The current environment is forcing group practices to make operational changes that severely challenge their ability to provide quality care to Medicare beneficiaries,” Dr. Susan Turney, president and CEO of the MGMA-ACMPE said in an 18-page letter to CMS Administrator Marilyn Tavenner. “MGMA will continue to work with congressional leaders, urging them to permanently address the broken Medicare physician payment system and replace it with a more stable and predictable update mechanism that accounts for the actual cost of providing care to Medicare beneficiaries.”
Turney also noted her organization's opposition to the proposed policy, which resulted in reducing payment for 211 billing codes for services performed in a physician office to match the lower payments for the same services rendered in a hospital outpatient department or ambulatory surgery center. She urged the CMS “to use extreme caution” in adopting policies that “dramatically impact physician payment.”
Turney cited an AMA analysis of the proposal that reduced reimbursement would result in several instances where the new lower payments would not cover physician labor, supply and equipment expenses.
While Turney's letter also noted her support and appreciation for the CMS proposal to pay for more chronic-care coordination services starting in 2015, it said requirements for such payments would backfire. “Overall, while we support establishing Medicare payment for complex chronic care management, CMS' proposal is very onerous and, if finalized, would dramatically limit the ability of beneficiaries to receive these services,” Turney wrote.
Turney also urged Tavenner to immediately address the “burdensome” reporting requirements of the multiple federal quality-improvement programs. “Physicians should meet government quality reporting criteria by reporting through a single program—not four,” Turney wrote.
Turney's comments were echoed by the American Medical Association. In a 59-page letter to Tavenner (PDF), AMA Executive Vice President and CEO Dr. James Madara “implores” the CMS to rescind its proposal to cap physician office billings at the same level as payments in hospital outpatient settings or ASCs.
“We strongly dispute the fundamental premise behind this proposal, that higher payment rates for services in physicians' offices must be based upon inaccurate data,” Madara wrote. “This proposal's underlying premise is irreparably flawed.”
Madara applauded the proposal to pay for nonface-to-face complex chronic-care management services. But he criticized an idea floated by the CMS that a practice needs to get third-party certification as a patient-centered medical home in order to prove their ability to provide care coordination and management.
“We believe that any physician practice which meets the practice requirements should be able to qualify for payment of CCCM services, regardless of certification as a medical home,” Madara wrote. “We strongly disagree that employment of advanced practice nurses and/or physician assistants is an appropriate requirement for practices to bill these services.”
Dr. Glen Stream, board chairman of the American Academy of Family Physician, began his 21-page letter to Tavenner (PDF) by noting that a family doctor in solo practice could lose almost $90,000 if the 24.4% SGR pay cut went in effect.
The AAFP commended the CMS for proposing to pay for chronic-care management. But the group noted that the current coding system does not adequately value the evaluation and management services provided by family doctors and recommended that the CMS create dedicated codes for primary-care physicians.