The California Medical Association (CMA) recently submitted comprehensive comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2019 Medicare Physician Fee Schedule and MACRA Quality Payment Program rule.

CMA is supporting CMS’s proposal to substantially reduce the Evaluation and Management (E/M) documentation requirements because it would reduce note bloat, improve workflow, and allow physicians to devote more time to their patients.

However, CMA is strongly opposed to the proposal to restructure payment and coding for (E/M) office visits by collapsing the codes from five to two for both new and established patients. Even with the new proposed add-on codes for prolonged visits, primary care and certain specialties treating sicker patients, the proposal would result in significant payment cuts that would harm physicians in specialties that treat the sickest patients, as well as those who provide comprehensive primary care. Collapsing E/M codes as proposed would jeopardize access to care for the chronically ill and patients with complex conditions.

CMA believes there are a number of unanswered questions and potential unintended consequences that would result from the coding policies in the proposed rule. CMA strongly recommends that CMS work with CMA and the proposed American Medical Association task force to develop alternative solutions.  

CMA also strongly opposes the new multiple service payment reduction policy in the proposed rule, as the issue of multiple services on the same day of service was factored into prior valuations of the affected codes and is an important payment for physicians, as well as patient convenience.

Provisions CMA supports:

• Year 3 of the CMA-sponsored California geographic payment updates and the transition to metropolitan statistical areas
• New payments for technology-based and telehealth services
• E/M documentation reduction
• Eliminating extra documentation requirements for home visits
• Eliminating the prohibition on billing for same-day visits by physicians in the same group or medical specialty

Provisions CMA opposes:

• New E/M payment structure
• Multiple procedure payment reduction
• Reimbursement reduction for new drugs administered in physician offices
• Reporting expansion for physician office labs

For more information:

• CMA’s Comments on the Proposed Medicare Physician Payment Rule
• AMA Summary of the Proposed Rule
• California Geographic Payment Impact Analysis
• Specialty Specific Impacts Including Payment Accuracy Adjustments
• Estimated Impact of CY2019 Evaluation and Management Proposed Policy by Medicare Specialty
• Estimated Impact on Total Allowed Charges by Specialty