MGMA comments on proposed 2010 Physician Fee Schedule

The Medical Group Management Association (MGMA) submitted comments on Aug. 28 about the proposed 2010 Physician Fee Schedule. Based on MGMA members' input, MGMA commented on the Centers for Medicare & Medicaid Services proposals in four areas. 

• Physician Quality Reporting Initiative (PQRI)
  MGMA urges CMS to quickly finalize testing the PQRI reporting mechanism via electronic health records (EHRs), allow for 2010 PQRI participation through qualified EHRs, and release the EHR measure specification information to vendors in an expedited fashion.
  
  MGMA opposes CMS' proposed definition of a group practice for purposes of the new PQRI group practice reporting option. Instead, the Agency should allow any interested group, regardless of size, to report on the proposed measures through a properly structured group practice reporting mechanism.
  
  
• Equipment usage assumption
  MGMA opposes the increased utilization assumption for all equipment priced at over $1 million. The change is based on erroneous assumptions and will result in a payment rate so low as to make it economically unfeasible for physicians to perform imaging services in their offices.
  
  
• Implementation of  physician accreditation standards
  MGMA has concerns about several proposed provisions implementing the accreditation requirements for advanced diagnostic imaging services in the Medicare Improvements for Patients & Providers Act (MIPPA). In some instances, the Agency has suggested changes that unnecessarily expand on the statutory requirements for entities seeking to be designated as accrediting bodies, which would ultimately have a negative effect on the suppliers of advanced diagnostic imaging services.
  
  
• Physician resource use measurement and reporting  
  MGMA remains extremely concerned over the Agency's continued use of proprietary commercial episode grouper software, since transparency is one of the primary goals of CMS' Value Based Purchasing (VBP) initiatives. Given the importance of quality improvement to MGMA, the Association agrees that quality measure information should be included in the Resource Use Reports; however, reliable quality measurement data must be used.

Read MGMA's full comments

See how the proposed 2010 Physician Fee Schedule affects medical group practices