Statement on Proposed CY 2019 Physician Fee Schedule (PFS) Rule

Tom Nickels
Executive Vice President
American Hospital Association

July 12, 2018



Today’s proposed policies from CMS will provide opportunities and challenges for hospitals and health systems and the patients and communities they are proud to serve each day.

We applaud CMS for taking action to reduce the regulatory burden hospitals and health systems face, including advancing their “Meaningful Measures” initiative. This also includes better aligning the Promoting Interoperability Performance Category in the Quality Payment Program with the interoperability program proposed for hospitals in the inpatient rule. We also are pleased to see CMS taking some steps to expand the ability of physicians to serve patients through telehealth and virtual connections.

On the other hand, we remain disappointed that CMS continues its short-sighted policies on the relocation of existing off-campus hospital outpatient departments. These “site-neutral” policies ignore the need for hospitals to modernize existing facilities so that they can provide the most up-to-date, high-quality services to their patients and communities. We also continue to urge CMS to improve its payment methodology to better account for the fact that the outpatient payment system includes many more services in its payment rates than the PFS.

We are also concerned about reductions in payments for certain new drugs – we believe CMS should instead address the skyrocketing list prices of drugs directly with pharmaceutical manufacturers. In addition, providing substantially less ability to distinguish evaluation and management codes for different levels of resource use and intensity of services means that physicians who provide care for a disproportionate number of high-acuity patients would consistently, and unfairly, receive underpayment.




About the AHA

The AHA is a not-for-profit association of health care provider organizations and individuals that are committed to the health improvement of their communities. The AHA is the national advocate for its members, which include nearly 5,000 hospitals, health care systems, networks, other providers of care and 43,000 individual members. Founded in 1898, the AHA provides education for health care leaders and is a source of information on health care issues and trends. For more information, visit the AHA website at