Sept. 7, 2018
The Honorable Seema Verma
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
RE: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program
Dear Administrator Verma:
The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the proposed rule entitled, “Medicare Program: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program,” published on July 27, 2018, with file code CMS–1693–P.
MGMA is the premier association for professionals who lead medical practice. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures and specialties that deliver almost half of the healthcare in the United States.
MGMA supports CMS’ “Patients over Paperwork” Initiative, which the agency launched to reduce regulatory burden on physician practices who care for Medicare patients. We have made detailed recommendations below to assist CMS in achieving its stated goals of reducing clinician burden and improving patient care. MGMA highlights the following regulatory relief priorities for medical groups:
- Reconsider options for reducing documentation associated with E/M office visits without harming physician practices that treat the sickest patients. We urge CMS not to move forward with its proposal to collapse payment rates for eight office visits for new and established patients down to two each as there are many unanswered questions and potential unintended consequences that would result.