ACP offers recommendations to CMS’s 2018 Physician Fee Schedule proposal

In a letter to CMS, the American College of Physicians offered several recommendations on its proposed rule for the 2018 Medicare Physician Fee Schedule, focusing on further aligning various Medicare reporting programs and reducing administrative burdens for clinicians.

“As a practicing primary care internist, I am greatly encouraged that CMS is proposing substantial improvements to help me and my colleagues provide coordinated, patient-centered, high value and team-based care to our patients,” Jacqueline W. Fincher, MD, MACP, chair of the Medical Practice and Quality Committee for the American College of Physicians (ACP), said in a related press release. “We look forward to providing CMS with detailed comments to support these improvements while recommending other changes to strengthen primary care.”

One of the ACP’s top priority recommendations is for CMS to continue supporting the evaluation and management documentation reform. It emphasized that the care of the patient and advancing their care must be at the forefront of documentation.

The ACP also recommended further refining care management services codes and promoting enrollment in the program, reducing administrative burden, and aligning CMS and Current Procedural Terminology guidance coding requirements. The Appropriate Use Criteria for advanced diagnostic imaging services should be delayed until 2019 and a smaller version of the program should be implemented in the meantime during an evaluation period before its expansion, the ACP recommended.

In addition, the association recommended that CMS reduce or eliminate penalties from the “Pick Your Pace” policies associated with the Quality Payment Program and the Merit-Based Incentive Payment System (MIPS).

In the letter, the ACP noted several other important areas of the proposed rule that should be addressed, including chronic care management services; determination of proposed practice expense relative value units; Medicare telehealth services; changes to the Medicare Diabetes Prevention Program; payment rates under the Physician Fee Schedule for non-excepted items and services; Medicare Shared Savings Programs; Physician Quality Reporting System criteria; and the value-based payment modifier and physician feedback program.

In addition, the ACP also recommended that CMS improve its flexibilities and efficiencies by updating regulatory impact analyses for new and existing regulations, simplifying the scoring system for MIPS, simplifying and aligning the quality measurement system, and aligning varying policies, procedures and contracting arrangements in the Medicare Advantage Program with traditional Medicare.

Disclosure: Healio Internal Medicine was unable to confirm relevant financial disclosures at the time of publication.