AAPM&R Submits Comment Letter on Medicare Physician Fee Schedule

September 7, 2016

AAPM&R sent a comment letter to the Centers for Medicare and Medicaid Services (CMS) on September 6, 2016 regarding their proposed rule on the Physician Fee Schedule, named “Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model.” 

Comments, as discussed by the Reimbursement and Policy Review Committee (RPRC), focused primarily on coding issues. For example, the proposed rule included a proposal for CMS to pay an add-on fee when a physician treats a mobility-disabled patient requiring special equipment such as an adjustable examining table. Although the Academy supports the general idea due to its potential to increase access for disabled patients, we could not support the provision as it was proposed because the add-on payment would impose a higher co-pay on patients with disabilities than for patients without disabilities. Other comments included some suggestions concerning misvalued codes, as well as certain new or revised codes. The Academy also voiced strong disagreement with CMS’s proposal to require all physicians to collect and report data on actions related to global surgery codes, in 10 minute increments. CMS proposed the measure in order to collect data to potentially revise the current global surgery codes. Your Academy noted that this would impose a tremendous burden on physicians and suggested alternatives.  

Read the full comment letter.

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