This week, Your Academy submitted comments to the Medicare Physician Fee Schedule 2019 Proposed Rule. Our comments include extensive feedback on several issues including: the office and outpatient E/M proposals; proposed revalued codes; treatment for substance use disorders; the appropriate use criteria program for advanced diagnostic imaging services. The letter also includes comments on proposed changes to the Quality Payment Program, including: changes to the MIPS performance period; quality measure reporting; the MIPS data completeness threshold; implementation of episode-based measures for the cost category; facility measures; and advanced APMs.
The Academy comments are reflective of feedback we received from the membership over the past few months via our Town Hall, member survey, social media, and committee engagement. In addition to providing feedback to the Academy, many of our member #PMRAdvocates chose to reach out to CMS directly with their feedback on the proposed rule. Over 120 members submitted a template comment letter on the office and outpatient E/M proposals. Additionally, we are aware of several members crafting and submitting their own comments to CMS. CMS is required to read every comment submitted by the public, so individual and collective input on behalf of physiatry is impactful! Thank you to all members who engaged in these efforts to educate CMS on the devastating impact their E/M proposal would have on physiatry practices and patients.
In addition to our own comment letter, AAPM&R, as your primary medical society, actively participated in several coalitions to craft comments on various aspects of the proposed rule. This included weekly phone calls with a variety of specialty societies. Through these comment letters, the medical community worked together to fight the most egregious aspects of the proposed rule:
In addition to our advocacy on this issue with CMS, AAPM&R collaborated in an effort to oppose the E/M proposal on the Hill. Our multi-society House letter was sent to CMS on Friday, September 7 with 90 bipartisan signatures.
CMS typically publishes the Medicare Physician Fee Schedule Final Rule in early November. However, we have heard that CMS may work to make the final rule available earlier this year. AAPM&R will quickly disseminate information to members, once it is available. Until then, AAPM&R highly encourages members to be #PMRadvocates—participate in Voter Voice requests and share your perspective with AAPM&R as health care undergoes significant changes.