AMGA Supports E/M Coding Changes in Final Physician Payment
Expresses Disappointment at MIPS Update

Alexandria, VA – AMGA supports the Centers for Medicare & Medicaid Services’ (CMS’) decision to finalize changes to coding requirements for evaluation and management (E/M) services that acknowledge differences in patient complexity. In its final 2020 Physician Fee Schedule rule, CMS will maintain separate coding levels, rather than paying a blended rate.

AMGA was concerned that collapsing E/M levels 2 through 5, as initially proposed by CMS, would disrupt care coordination efforts and result in fragmentation, which would hinder the transition to value-based care. AMGA is pleased that CMS reconsidered its 2019 regulation and in this year’s final rule opted to assign a separate payment rate to each of the office and outpatient E/M visit codes. CMS also finalized its proposal to maintain the level 1 visit code for established patients. AMGA recommended this approach, as the level 1 code helps facilitate a team-based approach to care delivery and allows various members of the care delivery team to develop a relationship with a patient.

“A team-based approach to care requires an infrastructure to support it,” said Jerry Penso, M.D., M.B.A., AMGA president and CEO. “It also requires the right policies and a payment system that will maintain that infrastructure. This change goes a long way to helping our members deliver the best possible care.”

Disappointed in MIPS Updates

The rule also finalized changes to the Merit-based Incentive Payment System (MIPS). Overall, CMS expects Part B payment adjustments of 1.4% for those providers who participate in the program. However, Congress authorized up to a 9% payment adjustment for the 2020 performance year. While not every provider will achieve the highest possible adjustment, CMS’ continued policy of excluding otherwise eligible providers from participating in MIPS makes it impossible to achieve substantial payments to cover the cost of participation. Thus, AMGA members have expressed that the program is no longer a viable tool to for transitioning to value-based care. care.


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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