Update: AGS and Coalition Comments on the PROPOSED Medicare Physician Fee Schedule (MPFS) Rule for 2019 (#MPFS2019)

By Nancy Lundebjerg posted 09-13-2018 10:06 AM


I want to start with a big thank you to the AGS members who have participated in our grass-tops and grassroots outreach to your members of Congress.  To date, there have been two letters sent to CMS from Capitol Hill and there is an additional letter in the works.  The sent letters can be found here (House Ways and Means Committee) and here (House Sign-On led by Representatives Brad Wenstrup (R-OH), Earl Blumenauer (D-OR), Marsha Blackburn (R-TN), and Doris Matsui (D-CA)).

On Monday, AGS submitted two letters to the Centers for Medicare and Medicaid Services (CMS) that commented on the proposed rule.  The letters were the culmination of two-months of work by our superb public policy team which, in addition to generating the AGS comment letter led a coalition of 50+ organizations in developing a coalition comment  that, ultimately, was signed on to by 41 organizations.  The coalition, informally known as the Patient-Centered Evaluation and Management Coalition also submitted a letter to the Congressional committees that have been helpful on this issue (Senate Finance, House Ways and Means, and House Energy and Commerce) that had 40 signatories.

Saying I am #AGSProud of this work is putting it mildly.

Over the next month, we will be publishing two articles in JAGS that are focused on our payment work.  The first (Hard Work, Big Changes: American Geriatrics Society Efforts to Improve Payment for Geriatrics Care, slated to publish online next week) reports on our ongoing efforts to develop and value Current Procedural Terminology (CPT) codes that support high-quality, coordinated geriatrics care.  The second (which is in the final stages of editing) will focus on the Evaluation and Management Services (E/M) documentation and payment proposals that CMS put forward in the proposed #MPFS2019.  A summary of the E/M proposal can be found in my initial blog post here.  

The letter we sent to CMS on Monday, addressed a number of proposals in the rule but knowing that many members were concerned about the proposed changes to E/M, I want to highlight our comments on that proposal here.

We expressed our strong support for CMS immediately making the following changes to documentation:

  • Allow physicians the option to document visits based solely on the level of medical decision-making or the face-to-face time of the visit as an alternative to the current guidelines.
  • If physicians choose to continue using the current guidelines, limit required documentation of the patient’s history to the interval history since the previous visit (for established patients).
  • Eliminate the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient.
  • Eliminate the prohibition on billing same-day visits by practitioners of the same group and specialty.
  • Remove the need to justify providing a home visit instead of an office visit.

We expressed our opposition to the payment changes for outpatient/office visits that had been proposed by CMS, including the following:

  • collapsing of 99202-99205 and 99212-99215;
  • multiple procedure payment reduction; and
  • G codes for primary care and specialty adjustments and prolonged services.

We called on CMS to withdraw its proposed changes to E/M payment and engage with stakeholders to develop a refined approach that would achieve the best possible outcomes for patients, particularly frail older Americans with multiple chronic conditions.




09-16-2018 05:07 PM

Thank you very much. I think your suggestions are very valuable. It also supports the fact that current documentation requirements are burdensome and do not increase the quality of the notes. Change was needed. I hope the change will be in the right direction to decrease burden and improve patient care.

09-14-2018 10:24 PM

Thank you so very much for speaking on behalf of us all!

09-14-2018 05:35 PM

​Thanks--this work is critically important for our field and our patients and their families

09-14-2018 08:17 AM

Great work! Thanks to everyone at AGS who was involved!