The AHA appreciates the steps the Centers for Medicare & Medicaid Services is taking to streamline the Quality Payment Program and reduce burden for clinicians, but “is very concerned about the collapse of payment rates for evaluation and management visit codes,” which could cut payments to physicians who see the sickest patients and threaten patient access to care, AHA said in comments submitted today on the physician fee schedule proposed rule for calendar year 2019. In its letter, AHA shares recommendations related to proposed changes to payment and documentation requirements for evaluation and management visits; payment rates under the PFS for nonexcepted items and services furnished by nonexcepted off-campus provider-based departments of a hospital; appropriate use criteria for advanced diagnostic imaging services; wholesale acquisition cost-based payment; the clinical laboratory fee schedule; proposed changes to the Quality Payment Program; the promoting interoperability performance category in the Merit-based Incentive Payment System; and expansion of access to virtual care and telehealth.

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