126 Patient and Provider Groups to CMS: Proposed E/M Service Cuts Will Hurt Sickest Patients

A broad coalition of 126 patient and provider groups – led by leading national organizations including the American College of Rheumatology – today sent a letter to the Centers for Medicare and Medicaid Services (CMS) urging the agency not to move forward with a proposal that would significantly reduce Medicare reimbursements for evaluation and management (E/M) services provided by specialists, citing concerns that these time-intensive services – which include examinations, disease diagnosis and risk assessments, and care coordination – are already grossly under-compensated and that additional payment cuts would worsen workforce shortages in already strained specialties like rheumatology.

The proposal, which was included in the 2019 Physician Fee Schedule proposed rule, would consolidate billing codes for E/M office visits, resulting in a flat payment for all E/M visits regardless of the complexity of the visit. Though the proposal was intended to reduce Medicare provider documentation and reporting burdens, it would also result in significant payment cuts for specialty care involving face-to-face visits with patients who have complex care needs, penalizing doctors who treat sicker patients or patients with multiple, chronic conditions.

“We applaud CMS for recognizing the problems with the current evaluation and management documentation guidelines and codes and for including a significant proposal to address them in the CY 2019 physician fee schedule proposed rule,” the letter reads. “However, we urge CMS to reconsider this proposal to cut and consolidate evaluation and management services, which would severely reduce Medicare patients’ access to care by cutting payments for office visits, adversely affecting the care and treatment of patients with complex conditions, and potentially exacerbate physician workforce shortages.”

The groups warn that payment cuts of this magnitude will not only compromise patient access to care by forcing physicians to spend less time with their patents but could create a disastrous ripple effect throughout the U.S. health care system, discouraging medical students from pursuing specialties that provide complex care and disincentivizing doctors from taking new Medicare patients altogether.

“Not only will this will result in an additional burden on patients with more copayments and costs associated with time and travel, it will also reduce the quality of care, particularly for patients with complex medical conditions,” the letter continues.

The proposed cuts go against the recommendations of the Medicare Payment Advisory Commission (MedPAC), an independent advisory commission to the Medicare program, which earlier this year proposed increasing reimbursement for E/M services given the time and intensity they require, and that E/M services are already undervalued relative to other physician services.

“We therefore urge CMS not to move forward with the proposal as it currently stands, and instead convene stakeholders to identify other strategies to reduce paperwork and administrative burden that do not threaten patient access to care,” the letter concludes.

To view the letter, click here.

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