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

Ashley Thompson
Senior Vice President, Public Policy Analysis and Development
American Hospital Association

November 1, 2018

Today’s rule will have positive and negative consequences for America’s hospitals and health systems and the patients they serve. We applaud CMS for continuing to reduce regulatory burden and for expanding coverage of telehealth and virtual care. We also are pleased that the agency keeps a gradual and flexible approach to implementing the MACRA’s physician quality payment program, better aligns the promoting interoperability requirements for MIPS-eligible clinicians with those for hospitals, and expands the availability of MIPS facility-based measurement.

We also appreciate that the agency responded to our concerns and mitigated its proposal to consolidate evaluation and management codes for providers. CMS will now retain three levels of codes and delay implementation until 2021, which will allow us to work with the agency to ensure that physicians who treat a disproportionate number of higher-acuity patients are not financially penalized. 


However, we are disappointed that CMS will reduce payments for certain new drugs, and continue its short-sighted “site-neutral” policies that 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 physician fee schedule.


About the American Hospital Association

The AHA is a not-for-profit association of health care provider organizations and individuals that are committed to the improvement of health in their communities. The AHA is the national advocate for its members, which include nearly 5,000 hospitals, health care systems, networks and other providers of care. 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





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