September 20, 2019
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; CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies and the Quality Payment 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; CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies,” published on
August 14, 2019, with file code CMS–1715—P. MGMA is the premier association for professionals who lead medical practices. 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 45,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 practices of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.
MGMA appreciates CMS’ leadership in improving Medicare and respectfully offers the following recommendations to assist CMS in achieving its goals of reducing clinician burden and improving patient care. In summary, we encourage the agency to:
Download the full letter
- Finalize the proposal to maintain separate payment rates for E/M visit levels for established patients and reduce the number of levels for new patients by deleting CPT code 99201. We appreciate CMS’ proposal to revise the previously finalized E/M payment changes and align them with the CPT/RUC recommendations.