The American College of Physicians (ACP) has voiced strong opposition to proposed changes in payments for evaluation and management (E/M) codes, arguing that they fail to appropriately recognize the value of cognitive care required for treating complex patients. As part of the proposed 2019 Medicare Fee Schedule (MFS) and Quality Payment Program (QPP) rules, these changes, ACP asserts, should not be implemented.
In its comments to the agency, ACP acknowledged the proposal’s positive steps toward reducing documentation burdens for E/M services—an issue the organization has long urged CMS to address. However, ACP emphasized that these improvements should not be contingent on accepting the payment changes. Instead, CMS should collaborate with physicians to develop a more effective approach rather than rushing to meet an arbitrary deadline next summer.
“While we appreciate the efforts to reduce documentation burdens in alignment with our Patients Before Paperwork initiative, we are deeply concerned that the proposed equal payment for complex cognitive care and basic care will ultimately harm the patients who need us the most,” said Dr. Ana María López, MD, MPH, FACP, president of ACP. “If implemented as proposed, many physicians treating frail, sick, or medically complex patients would face financial disadvantages, discouraging them from spending the necessary time with these individuals.”
ACP’s feedback was included in a letter submitted to CMS Administrator Seema Verma, signed by Dr. Jacqueline Fincher, MD, MACP, chair of ACP’s Medical Practice and Quality Committee. Along with addressing the E/M payment changes, the letter outlined ACP’s full set of recommendations and concerns regarding the proposed 2019 fee schedule and QPP, advocating for alternative solutions to CMS’s flat fee proposals.
“ACP believes that CMS should engage with the physician community to explore alternative approaches that balance documentation relief with fair payment structures for E/M services,” said Dr. López. “Reducing documentation burdens is critical to addressing widespread physician concerns, including issues related to EHRs and excessive documentation requirements. ACP is open to developing and testing blended payment models that allow for differentiated payment rates based on complexity while ensuring documentation requirements remain simplified and aligned with CMS’s program integrity goals.”
The letter also included several additional recommendations, such as:
- Improving the Merit-based Incentive Payment System (MIPS) by reducing administrative burdens, streamlining scoring, increasing flexibility, and maximizing participation through the proposed “opt-in” option for those currently excluded under the low-volume threshold.
- Implementing MIPS changes gradually, including maintaining the current weight of the Cost Category and avoiding abrupt increases in the performance threshold.
- Allowing a phased approach for adopting 2015 Certified EHR Technology (CEHRT).
- Avoiding unreliable measures in the Quality Performance Category of MIPS, particularly proposed episode-based cost measures.
- Enhancing opportunities for small and rural practices to succeed under QPP.
- Supporting the proposed January 1 implementation of payments for virtual visits and other non-face-to-face cognitive services.
“We urge CMS to carefully consider the feedback from ACP and other physician organizations before finalizing these rules, particularly regarding E/M payment changes,” Dr. López added. “Our goal is to collaborate with CMS to develop a plan that eases E/M documentation burdens while ensuring fair compensation for the complex cognitive care that patients deserve