CMS Physician Fee Schedule Proposals Create Uncertainty for AMGA Members

Alexandria, VA – AMGA is concerned that the Centers for Medicare & Medicaid Services (CMS) proposed CY 2021 Physician Fee Schedule rule would inadvertently exacerbate the financial situation facing our membership that is a result of the ongoing novel coronavirus 2019 (COVID-19) pandemic. While appreciative of the effort to increase support for primary care services, the Physician Fee Schedule’s budget neutrality requirements effectively shift funds from one specialty to another, potentially undermining the team-based approach to care that is the hallmark of the group practice model.

“More than anything right now, our members need certainty,” said AMGA President and CEO Jerry Penso, M.D., M.B.A. “CMS’ plan unfortunately would add yet another change into a system that is dealing with an upheaval in how care is provided. From canceled elective procedures to a rapid shift to telehealth, group practices are working to not only get their bearings and recognize what care delivery models are most effective for treating patients during this pandemic, but also to understand what practice patterns will be like after COVID-19. Changes to code values just add more uncertainty.”

In their comments to CMS, AMGA specifically recommends that the agency not move forward with its proposal to revalue a number of office and outpatient evaluation and management (E/M) visits. The reduction in the conversion factor needed to maintain budget neutrality represents a significant decrease in support for Medicare providers and would decrease payments for a number of providers.  

AMGA also is opposed to CMS’ proposals for the Medicare Shared Savings Program (MSSP), such as a proposed reduction in the number of quality measures that accountable care organizations (ACOs) will report and the elimination of the pay-for-reporting year for ACOs in their initial contract. CMS also would revise the quality performance standard so it creates an “all-or-nothing” ability for an ACO to earn shared savings. AMGA opposes these changes, which increase the influence of any one measure on an ACO’s ability to earn shared savings. These significant proposals come shortly after CMS finalized a new structure to the ACO program in 2018.

“Our members understand that CMS is going to make technical adjustments to the ACO program during a contract period,” Penso said. “This rule goes beyond that and would significantly alter the program not even two years after CMS finalized a major overhaul of the MSSP.”  

The letter is available on the AMGA website.


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.


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