Letter: Physician Fee Schedule Proposed Rule for CY 2019

Download the comment letter (PDF)

RE: CMS-1693-P, Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, and our clinician partners – including more than 270,000 affiliated physicians, 2 million nurses and other caregivers – and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) physician fee schedule (PFS) proposed rule for calendar year (CY) 2019.

The AHA appreciates the steps CMS is taking to give providers more time to focus on their patients by streamlining elements of the Quality Payment Program and reducing burden for clinicians. However, we are very concerned about CMS’s proposal to collapse the payment rates for evaluation & management (E/M) visit codes, which would disproportionately impact hospital-based physicians who see the sickest patients and could reduce patient access to care.

Specifically, our key recommendations follow in the letter below.

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