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Sharon Grace
Chief Communications Officer
703.838.0033 ext. 393
sgrace@amga.org

September 26, 2019

AMGA Pleased CMS Reverses Evaluation and Management Policy
Offers Assistance to Develop MIPS Value Pathways

Alexandria, VA – AMGA today endorsed the Centers for Medicare & Medicaid Services (CMS) proposed changes for office visit payments and offered to work with the agency to develop a reformed reporting system for the Merit-based Incentive Payment System (MIPS). AGMA’s comments are in response to the CY 2020 Physician Fee Schedule proposed rule (CMS-1715-P).

AMGA recommended that CMS finalize its proposal to pay separate rates for office and outpatient Evaluation and Management (E/M) visit codes. In this year’s proposal, CMS responded to AMGA’s and other stakeholders’ concerns with the 2019 Physician Fee Schedule, which would have implemented a policy to pay a blended rate for E/M services, by proposing to reinstate payments that account for the differences in the time and resources providers need to treat patients with more complex healthcare needs. AMGA recommended that CMS finalize its proposal to assign a separate payment for these office services. AMGA also endorsed CMS’ proposed changes to documentation requirements, which will enable providers to choose medical decision-making or time when documenting for payment purposes.

“CMS recognized that its earlier plan for E/M visits would have disrupted care patterns and may have created other unintended consequences,” said Jerry Penso, M.D., M.B.A., AMGA president and CEO. “Having the separate codes helps acknowledge the difference in resources in treating patients with more complex care needs.”

AMGA expressed appreciation for the novel approach to MIPS reporting and scoring that CMS is considering through its MIPS Value Pathways (MVP). Designing a reporting and scoring mechanism around a specific disease has merit, but AMGA recommends that CMS not move forward at this time. Before implementing such a model, CMS needs to ensure it appropriately addresses beneficiary attribution. As it stands, MIPS is a retrospective model. Prospective assignment is needed so that providers know which patients are included for reporting purposes. AMGA expressed that it would be pleased to work with CMS to develop the MVP framework.

“CMS is interested in building a MIPS model around a specific condition,” Penso said. “Instead of moving forward with a concept based on selecting quality measures, we can work with CMS to build a framework that is designed based on the care patterns and practice models that are inherent in group practices. That way, care delivery is driving measurement, rather than measurement influencing how care in delivered.”

AMGA also opposed the continuation of the MIPS low-volume threshold, which excludes otherwise eligible clinicians from the program and reduces the opportunity for high-performing providers to earn a significant payment adjustment.

AMGA’s letter is available here.

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About AMGA
AMGA is a trade association leading the transformation of health care in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans.