While it supports CMS simplifying documentation requirements for physician evaluation and management visits, trade association AMGA, formerly the American Medical Group Association, said it opposes certain coding changes proposed by the federal agency.
AMGA, which represents more than 450 multispecialty medical groups and integrated delivery systems, made the remarks in a Sept. 10 letter responding to CMS' annual update to the Medicare Physician Fee Schedule.
The 2019 proposed physician payment rule published in July calls for implementing a multiple-procedure payment adjustment that would collapse level two through five office visit codes to a single blended payment rate when the visits take place at the same time as other procedures.
The association's letter states CMS would also allow providers to choose how they document evaluation and management visits by: choice of time, medical decision making or use of the current 1990s-era documentation frameworks.
In its letter, the association said it believes CMS "is confounding two separate issues by proposing to collapse level two through five [evaluation and management] codes. Documentation requirements are unrelated to the complexity of a beneficiary's care needs represented by a billing code."
"Providing physicians with a choice in how to document beneficiary evaluation and management visits would be a welcome development," said Jerry Penso, MD, the association's president and CEO. "It indicates CMS is serious about addressing administrative burden, particularly since these billing codes represent nearly one-third of all Medicare physician visits.
"Unfortunately, pairing paperwork reforms with a significant change in categorizing patient complexity and reimbursement may very likely undermine care quality and coordination and cause disruption in physician workflow and referral patterns," Dr. Penso said.
In addition to concerns about coding changes, the association said it remains opposed to high Merit-based Incentive Payment System exclusion thresholds in the CMS proposed physician payment rule for 2019.
Read the association's full letter to CMS here.
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