A proposal to overhaul Medicare’s evaluation and management (E&M) payment levels would significantly reduce physicians’ payments and damage access to care, the Texas Medical Association and nine other state medical societies say in a letter to the Centers for Medicare & Medicaid Services.
“This proposal significantly devalues the work physicians perform and the services we provide,” TMA and the others wrote.
The letter from the Coalition of State Medical Societies, sent to CMS Administrator Seema Verma on Thursday, urges CMS to reconsider its physician fee schedule rule proposal for 2019. The societies commented together “because we are extremely concerned about how badly this particular proposal would hurt our member physicians and their patients,” the letter says.
The CMS plan would collapse the five levels of office-visit payment for both new and established patients down to two levels, with one payment rate for level 1 visits and another covering levels 2-5. The rule projects the higher payment level to fall between the payment for levels 3 and 4 in the current structure — meaning physicians who typically handle level 4 and 5 visits for more complex patients would see their payments take a hit. The coalition noted that an impact analysis by the American Medical Association projects payment cuts of up to 20 percent.
TMA and the rest of the coalition warn Administrator Verma that the changes would especially mar access to care for Medicare patients with chronic or complex medical problems.
The letter warns that the new payment structure would eliminate incentives for physicians to care for complex patients, lead more physicians to limit their Medicare patient panels, and cause commercial insurers to follow Medicare’s lead, as they often do on payment matters.
TMA and the other societies praised efforts in the CMS proposal to simplify dated and unnecessary documentation requirements. But the proposed flattening of payments “erroneously assumes the greater documentation requirement is the only justification for the larger payments currently provided for those visits,” the coalition wrote.
“This is an extension of the thinking that transformed the medical record from an essential clinical tool into a billing-support document,” the letter says. “Regardless of any payers’ requirements, physicians will continue to use the medical record to document their clinical findings, assessment, and plans. Regardless of any payers’ requirements, the amount of time, expertise, and skill used with the patient will not change.”
TMA is finalizing its own detailed comments on the entire rule and will share them with membership when they’re submitted to CMS. Members can submit comments until the comment period closes on Sept. 10. CMS is expected to issue the final rule by Nov. 1.
Along with TMA, the Coalition of State Medical Societies includes the state medical associations in Arizona, California, Florida, Louisiana, New Jersey, New York, North Carolina, Oklahoma, and South Carolina.