Nearly 300 patient and provider groups and other health organizations sent two separate letters to CMS Administrator Seema Verma to protest proposed evaluation and management (E/M) service changes in the 2019 Physician Payment Rule.
A letter that included the American Medical Association and about 150 other groups did praise the rule's effort to cut back on physician paperwork.
- However, another letter that was signed by 126 groups said "this proposed approach to reducing paperwork would have unintended consequences for Medicare beneficiaries" like doctors responding to the rate cuts by spending less time with patients or cherry-picking the healthiest patients.
CMS proposed a change in its 2019 physician fee schedule that would consolidate billing codes for E/M office visits. It's part of a move to reduce Medicare provider documentation and reporting burdens. However, opponents to the proposal say it will hurt specialists and lead to flat payments for all E/M visits regardless of complexity.
Doctors are generally onboard with proposals that reduce required documentation and red tape, but a substantial change in the way payments are calculated has many of them uneasy and speculating a harmful fallout.
The American Medical Association's letter with about 150 medical groups said the groups support CMS' "Patients Over Paperwork" initiative. The agency has promoted efforts to reduce providers' administrative burdens through changing and reducing regulations.
Proposed documentation changes that will cut administrative tasks include allowing providers to document only the interval history since the last visit, eliminating the requirement that physician re-document information and not forcing providers to justify a home visit rather than an office visit.
In its letter, the organizations praised the attempt to reduce "note bloat." One of the groups that signed the letter, the American Academy of Family Physicians, said earlier this year that rules and paperwork burdens are "untenable" for family physicians. At the time, the group offered seven ways to reduce that burden.
The medical groups writing to CMS were concerned, however, with the proposal to collapse payment rates for eight office visit services for new and established patients down to two each.
"We oppose the implementation of this proposal because it could hurt physicians and other healthcare professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients' access to care," according to the letter.
The other letter states that specialist services are already "grossly under-compensated" and additional cuts would make workforce shortages worse, including in specialties like rheumatology. "Not only will this will result in an additional burden on patients with more copayments and costs associated with time and travel, it will also reduce the quality of care, particularly for patients with complex medical conditions," the letter reads.
Rather than move forward with the proposal, the organizations suggested that CMS convene stakeholders "to identify other strategies to reduce paperwork and administrative burden that do not threaten patient access to care."