ACR warns CMS against reimbursement cuts for evaluation, management services

David Daikh

In a letter to CMS this week, the American College of Rheumatology renewed its call to repeal the 2019 Medicare Physician Fee Schedule proposed rule that would reduce physician reimbursement for evaluation and management services, arguing it would severely curtail patients access to care and “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,” David Daikh, MD, PhD, president of the ACR, said in a press release. “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.”

According to the ACR, the CMS proposal would institute a flat payment for evaluation and management visits, regardless of complexity. This, Daikh argues, would result in significant payment cuts for rheumatologists treating patients with complex care needs, thus penalizing physicians who treat patients with multiple chronic conditions.

The American College of Rheumatology this week renewed its call to repeal the 2019 Medicare Physician Fee Schedule proposed rule that would reduce physician reimbursement for evaluation and management services.

Source: HHS

Daikh added that the proposed cuts also contradict the recommendations of the Medicare Payment Advisory Commission, which earlier this year proposed increased reimbursement for evaluation and management services. The commission further argued that such services require extensive time and intensity on the part of physicians, and that such services are already undervalued.

The ACR additionally expressed deep concern regarding CMS’ proposal to reduce reimbursements for procedures performed on the same day and billed as a separately identifiable evaluation and management visit, warning it would force patients to return on a different day for minor procedures, increasing copays and potentially reducing quality of care.

In its letter, the ACR recommended that CMS table the potential payment changes and instead implement only the documentation relief elements of the evaluation and management proposal, so that CMS can more closely work with 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.”

Other ACR recommendations included:

Maintaining the Merit-Based Incentive Payment System (MIPS) small practice bonus at 5% of the final score, rather than move it to the quality performance category as the 2019 fee schedule currently proposes;
Nix a proposal to increase the weight of the cost performance category to 15% in the 2021 MIPS payment year, and use the best 90 days in the “cost” category when calculating MIPS payment bonuses, excluding Medicare Part B medication costs from the cost performance category;
Give physicians more credit for participating in specialty clinical data registries under MIPS; and
Accept stakeholder input regarding “inappropriate and excessive” reimbursement decreases for diagnostic ultrasounds 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,” Daikh said in the release. “We look forward to serving as a resource for CMS as it develops and implements its final 2019 Physician Fee Schedule rule.” – by Jason Laday