CMS Releases 2019 Physician Fee Schedule Proposed Rule

Members & Publications

July 16, 2018

UPDATE: Join us for a Virtual Town Hall on August 8 at 11:30 am CT to provide us with your input on how these policies will impact your practice. 


On July 12, 2018 the Centers for Medicare & Medicaid Services released the CY 2019 Medicare Physician Fee Schedule proposed rule. The rule includes many proposed provisions which would impact physiatrists. 

While we continue to review the proposals, we wanted to immediately alert you to the dramatic changes proposed to Evaluation and Management (E/M) payment and documentation requirements, as well as proposed reductions for services provided on the same day as E/M.  With E/M office visits comprising approximately 20% of allowed charges billed to the physician fee schedule, these policies stand to have a significant impact across medical specialties, including physiatry. All of medicine will be voicing its concern over these proposals, and we plan to be an active, loud voice representing the physiatry, and collaborating where possible.

Changes to E/M Payment
CMS is proposing to collapse payment for four levels of E/M into a single rate.  Under this proposal, high complexity office visits (level 5) will be cut by $76 (-36%) for new patients and $55 (-37%) for established patients. 

Changes to Payment for New Patient Office Visits


Current Payment

Proposed Payment














Changes to Payment for Established Patient Office Visits


Current Payment

Proposed Payment













Modifier 25 Reduction
Further, CMS proposes to reduce payment for E/M services billed with modifier 25.  While this proposal could negatively impact many physicians, physiatrists are likeliest to experience cuts when billing for medically necessary injections on the same day as providing E/M.  Members may recall that AAPM&R successfully fought a similar proposed Anthem policy early this year.   

Academy Actions
The E/M proposals outlined by CMS pose a threat to your ability to provide the high-quality, comprehensive care physiatric patients need.  AAPM&R will submit a comprehensive comment letter to CMS by the September 10 deadline, detailing the negative impacts these policies will have on Physiatry. We need your testimonies—how your patients will be negatively impacted by these proposals.

We also intend to partner with the greater physician community to combat the proposals. We will keep you informed of these efforts. 

On behalf of the Reimbursement Policy Review Committee (RPRC), we thank you in advance for your voice and attention to this important matter.

CMS is proposing to change Evaluation and Management documentation requirements and payment. Further, the rule proposes to expand payment for remote monitoring and interprofessional consultations. The rule also contains proposals to update the Merit-based Incentive Payment System (MIPS) for performance year 2019. 

Legislation Introduced to Alleviate Impact of Conversion Factor Cut for 2021

Nov 09, 2020

Last month, two bills were introduced in the House proposing solutions to the estimated 10.6% Physician Fee Schedule conversion factor cut expected to go into effect January 1, 2021.  The bills offer some relief to the cut, but do not reflect a comprehensive or long-term solution.  AAPM&R has therefore chosen to remain neutral regarding these bills. 

Your Academy continues to advocate for a permanent solution to the conversion factor cut while maintaining the important payment increases to office and outpatient evaluation and management services.