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Association Comments on 2019 Physician Fee Schedule Proposed Rule

In response to the calendar year (CY) 2019 Physician Fee Schedule proposed rule, America’s Essential Hospitals urged the Centers for Medicare & Medicaid Services (CMS) to adequately reimburse off-campus, provider-based departments (PBDs) and refine physician quality reporting to account for costs of care and the unique needs and patient populations served by essential hospitals.

In a Sept. 10 letter, the association opposed proposals to maintain cuts to reimbursement at non-excepted PBDs and to consolidate payment rates for evaluation and management (E/M) visits. The association also weighed in on year-three proposed updates to the Quality Payment Program.

America’s Essential Hospitals recommended that CMS:

  • ensure non-excepted PBDs under the Bipartisan Budget Act (BBA) are adequately reimbursed for the costs of care by paying them at least 75 percent of the OPPS rate, instead of 40 percent as proposed;
  • preserve access to complex specialty care at essential hospitals through adequate reimbursement of E/M visits;
  • finalize proposed changes that offer physicians flexibility on E/M coding documentation requirements;
  • continue to refine the measure set used to establish accountable care organization (ACO) quality performance standards under the Medicare Shared Savings Program (MSSP);
  • implement the facility-based measurement option for the Merit-based Incentives Payment System (MIPS);
  • continue to refine the measures included in the MIPS, including by risk adjusting when warranted;
  • implement policies that reduce burden and provide flexibility to providers in the promoting interoperability category of the MIPS;
  • maintain its policy of bonus points for MIPS-eligible clinicians who care for complex patients;
  • continue to engage stakeholders in development of Other Payer Advanced Alternative Payment Models (APMs);
  • engage stakeholders in the development of future models to encourage essential hospital participation in APMs;
  • improve patient access to critical services by expanding Medicare coverage and payment for services provided through telecommunications technology;
  • ensure efforts to improve transparency account for existing reporting requirements and sociodemographic variation among patients, and do not add administrative burden to providers; and
  • encourage improved communication between providers and patients without putting further burden on essential hospitals.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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