Medicare’s historic proposal to change how it pays physicians

The word “historic” is often used by PR professionals to hype something that is, well, pretty run-of-the-mill.  They figure that no one is going to read a news release that announces “[Name of organization] proposes small change that really won’t make much of a difference.”  The problem is that when something is done that really measures up to being historic, the recipient is less likely to believe it, kind of like the constant breaking news chyrons loved by cable news shows.

Recently, CMS — the agency that runs Medicare — issued a press release announcing “Historic Changes to Modernize Medicare and Restore the Doctor-Patient Relationship.”  You know what? This one may actually live up to the billing!

CMS is proposing to radically overhaul how it pays physicians for office visits and other evaluation and management (E/M) services; to lift restrictions on payment for telehealth consults and other physician services that are not part of the office visit itself; and to ease the myriad of crushing administrative tasks imposed on physicians to document their services or to get credit for participating in Medicare’s Quality Payment Program.

Both of CMS’s proposed rules are thousands of pages long, so few readers of this blog will be up to reading them. (Never mind trying to decipher the technical and legalistic language used for federal rulemaking!)  Fortunately, ACP’s crackerjack regulatory affairs staff was at it late last night and early this morning (when do they sleep?), to go through it and find out what is to like, and not like, about it.

They found that there is much to like.  Based on their review, ACP released a statement just a short while ago that expressed optimism that many of the proposed changes will “streamline burdensome administrative and documentation requirements — a proposal that is in line with ACP’s Patients Before Paperwork initiative” as Ana María López, MD, MPH, FACP, president, ACP, put it.  ACP also cautioned, though, that one of the biggest changes proposed by CMS — paying a flat fee for most office visits, regardless of their complexity — needed greater examination because of its potential to undervalue the skill and training required of physicians to take care of patients with more complex medical conditions.

There are 4 big changes proposed by CMS that are noteworthy:

1. CMS proposes to make it less burdensome for physicians to participate in its Quality Payment Program, including streamlining the Promoting Interoperability MIPS category by removing the separate components within the Promoting Interoperability (formally Advancing Care Information) Category score to create a streamlined scoring methodology, increasing the ways in which physicians and other clinicians can qualify for the low-volume threshold  and removing a number of quality measures deemed by the agency to be of low-value, consistent with recommendations by ACP and its Performance Measurement Committee.

2. CMS proposes to pay for more physician services that are not part of a face-to-face office visit. CMS proposes to add new reimbursable codes for “virtual check-ins,” remote consults of patient videos and photos, and interprofessional online consultations.

3. CMS proposes to take major steps to reduce the documentation requirements associated with evaluation and management (E/M) services, by allowing medical decision making to be the basis for documentation, requiring physicians to only document changed information for established patients and to sign-off on basic information documented by practice staff. ACP strongly supports these changes, as they will reduce the documentation burden on clinicians, limit redundant information in the medical record, and cut down on duplicative time spent on re-documenting existing information.  CMS also proposes to create add-on codes for primary care visit complexity.

4. CMS proposes to create a flat, single blended payment for most office visits, regardless of their complexity.  ACP expressed concern that this proposed payment structure potentially could have an adverse impact on internal medicine physicians and subspecialists and their patients, since internists typically take care of elderly patients with multiple chronic conditions.  “While we acknowledge the potential benefit of simplifying billing and associated documentation of E/M services by bundling levels 2-5 together, ACP will be assessing whether this change will have the unintended impact of undervaluing the work associated with caring for more complex and frail patients” Dr. López observed. “Reimbursing the most complex E/M services to such patients at the same flat level as healthier patients with less complex problems could undervalue the physician skills and training needed to care for such patients.”

There is much more to the proposed rules, including several areas where it fell short in ACP’s opinion.

Still, the overall direction of easing the burdens of participating in Medicare’s QPP, simplifying requirements to document office visits, paying for telehealth consultations and other work that falls outside of an office visit, and yes, the proposal to pay a flat fee for office visits of varying levels of complexity (whether this turns out to be a good idea or not after further examination of its impact), might just live up to being “historic.”

Bob Doherty is senior vice-president, governmental affairs and public policy, American College of Physicians and blogs at the ACP Advocate Blog.

Image credit: Shutterstock.com

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