Comments on 2019 Medicare Physician Fee Schedule Proposed Rule

Sep 10, 2018

ASRA has shared its feedback on the Centers for Medicare & Medicaid Services (CMS) 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 Promoting Medicaid Interoperability” (CMS-1693-P) in a letter sent September 10th.

The letter comments on 21 proposals in the proposed rule:

  1. Creating a bundled episode of care for management and counseling treatment for substance use disorders including opioid disorder
  2. Preventing opioid disorder in Medicare beneficiaries, including use of non-opioid alternatives for pain treatment and management
  3. Designating opioid-related measures as “high priority” quality measures in the Merit-based Incentive Payment System (MIPS)
  4. Adding new MIPS Promoting Interoperability opioid-related measure entitled “Query of Prescription Drug Monitoring Program”
  5. Adding new MIPS Promoting Interoperability opioid-related measure entitled “Verify Opioid Treatment Agreement”
  6. Adding the criterion of public health emergencies like the opioid epidemic to the MIPS Improvement Activities List
  7. Adding new MIPS Improvement Activity entitled “Patient Medication Risk Education”
  8. Addition new MIPS Improvement Activity entitled “Use of CDC Guideline for Clinical Decision Support to Prescribe Opioids for Chronic Pain via Clinical Decision Support”
  9. Recognizing inherently complex evaluation and management (E/M) visits in the Physician Fee Schedule (PFS), including those by pain management interventionalists
  10. Reducing provider documentation burden for evaluation and management (E/M) visits, particularly for proposed removals in redundancy of documentation requirements
  11. Opposing the proposed revisions to payments for E/M visits
  12. Eliminating of the current prohibition on same-day visits by practitioners of the same group and specialty
  13. Expanding of telemedicine services to Medicare beneficiaries
  14. Establishing separate payment for virtual check-in visits
  15. Creating separate payment for remote evaluation of pre-recorded patient information
  16. Establishing separate payment for interprofessional internet consultation
  17. Adding a new criterion to the MIPS low-volume threshold
  18. Continuing claims-based MIPS reporting for small and solo practices
  19. Expanding MIPS facility-based measurement to clinicians practicing in the on-campus hospital setting
  20. Continuing the MIPS complex patient bonus
  21. Opposing requiring providers to give price information to patients

To read more about specific feedback regarding each of these proposals, view the 12-page letter as a PDF.


Read more about ASRA’s advocacy efforts.

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