The proposed E/M payment changes that CMS floated last month are meeting with widespread criticism, with veteran physicians and other stakeholders calling for the agency to rethink its approach.
Not everyone is displeased with the direction that CMS is taking, which would blend the payment rate for levels 2 through 5 office encounter codes into a flat fee, but the vast majority of comments lean negative, according to a Part B News review of more than 3,000 public comments.
The following remarks highlight the issues and challenges that medical practice professionals think would occur should the pay proposal go forward as outlined:
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"I'm an endocrinologist in the Southeast U.S. who sees many complicated Medicare patients. Many of my patients are diabetic with heart disease, kidney disease and other medical complications. Most of my office visits are level 4 or 5 new and established. If these changes are made to Medicare reimbursement, my practice [will] lose tens of thousands of dollars. I will have to change my practice to limit Medicare patients and if needed will have to opt out of seeing Medicare patients to continue my practice. The idea that all medical evaluations are the same is ludicrous. This penalizes physicians like me who see complicated, sick older Americans. I am all for simplifying coding and billing, but reducing reimbursements on physicians that are already struggling to keep a practice open with high costs of EMR, staffing, [etc.], is not the answer.
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"I strongly disagree with this proposed revision. As a coder/biller in rheumatology, my physicians will be taking a considerable loss to their income with a flat rate payment as they see and treat very complex patients that need multiple visits and longer attention from the provider. I believe that you are taking a risk with patients’ health and care as physicians will need to see more patients in less time in order to compensate their loss of income."
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"This will be a killer to primary care physicians who are already struggling. We see highly complex patients and manage multiple issues per [appointment], and [this regulation] would be detrimental to the patient. It will force providers to cram more patients into a day just to break even. You will see [an] exodus from primary care and deter folks from going into a specialty already in short supply. Small practices will no longer be able to afford taking care of Medicare patients. Please do not do this!"
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"The proposed payment schedule is completely unacceptable and will force many physicians out of practice. The payment would be the same for a 20 minute new patient visit as it is for a visit lasting 60 or more minutes. How can this be fair? Patients with CMS are often very complicated and require a tremendous amount of time and expertise to evaluate and treat them and paying the same for evaluation of a healthy patient with a problem such as a sebaceous cyst as is being paid for a patient with hypertension, diabetes, coronary artery disease and morbid obesity who has a newly diagnosed breast or colon cancer is totally unwarranted. I suspect this will lead to many physicians opting out of Medicare and then Medicare beneficiaries will have an even more difficult time finding a physician who will treat them."
Amid a chorus of displeasure, there remains a smattering of support. The following comments show that the proposals have found favor among medical practice experts:
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"This is a great step to reduce all the craziness for documentation for physician visits. It will reduce the unnecessary burden of documenting things that are unnecessary and hopefully reduce a 20 page visit documentation, which other than the auditor, no one can read, to a common sense 1-2 page visit documentation which would be far more valuable to a fellow physician."
It remains to be seen which, if any, pieces of the proposed rule will take effect on Jan. 1. Despite the concerns being voiced en masse, previous Part B News analysis found that the pay rates for many specialties would increase significantly should the blended pay rate take effect. For those interested in having their voice heard, comments are due to CMS by Sept. 10.