AMGA Opposes E/M Coding Changes in Medicare Physician Payment Rule, Supports Documentation Reforms
Continues to Oppose High MIPS Exclusion Thresholds

Alexandria, VA – AMGA today encouraged the Centers for Medicare & Medicaid Services (CMS) to finalize proposed reforms to the documentation requirements associated with physician Evaluation and Management (E/M) codes, while detailing the association's concern with the agency’s plan to combine office and outpatient E/M Level 2-5 codes into one composite code.

Under the proposed physician fee schedule rule published in July, CMS would replace the current E/M codes with a new, single blended payment rate for E/M Level 2 through 5 visits. At the same time, CMS would apply a minimum documentation standard to provide Medicare Part B physicians with a choice of time, Medical Decision Making (MDM), or the use of the current 1995 or 1997 documentation guidelines. AMGA believes CMS is conflating two distinct or separate issues: documentation requirements and the complexity of a patient’s care needs represented by a billing code.

“Providing physicians with a choice in how to document beneficiary E/M visits would be a welcome development,” said AMGA President and CEO Jerry Penso, M.D., M.B.A. “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.”

AMGA Reiterates Opposition to High MIPS Exclusion Thresholds

The pending regulation also included CMS’ proposals for the CY 2019 performance year of the Quality Payment Program (QPP). CMS continues to propose high Merit-Based Incentive Payment System (MIPS) exclusion thresholds, which while intended to transition providers into the program, instead serves to undermine the efforts of those providers participating in the program already. However, CMS is proposing an avenue for excluded clinicians who would like to participate voluntarily to “opt in” to MIPS, which AMGA sees as a positive development. In addition, this policy improvement suggests CMS recognizes—as AMGA has argued—that excluding providers from the MIPS program is counterproductive for both those excluded and those included.

“Excluding providers from MIPS has a tangible impact on those clinicians who are working to succeed in the program,” said Penso. “AMGA members will continue to deliver high-value quality care, but these exclusions prevent MIPS from recognizing and rewarding their efforts to create value for Medicare.”

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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